&EPA
             United States
             Environmental Protection
             Agency
               Enforcement and
               Compliance Assurance
               (2221-A)
EPA310-R-00-003
September 2000
Profile of the Agricultural
Chemical,  Pesticide, and
Fertilizer Industry
 J.I. n
                 EPA Office of Compliance Sector Notebook Project

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Agricultural Chemical Industry
Sector Notebook Project
            EPA Office of Compliance Sector Notebook Project

      Profile of the Agricultural Chemical, Pesticide, and
                         Fertilizer Industry
                              Sebtemper 2000
                            Office of Compliance
                 Office of Enforcement and Compliance Assurance
                  United States Environmental Protection Agency
                  1200 Pennsylvania Avenue, NW (MC 2221-A)
                           Washington, DC 20460

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Agricultural Chemical Industry
Sector Notebook Project
This report is one in a series of volumes published by the United States Environmental Protection
Agency (EPA) to provide information of general interest regarding environmental issues associated
with specific industrial sectors. The documents were developed under contract by Abt Associates
(Cambridge, MA), Science Applications International Corporation (McLean, VA), and Booz-Allen
& Hamilton, Inc. (McLean, VA).  A listing of available Sector Notebooks is included on the
following page.

Obtaining copies:

Electronic versions of all sector notebooks are available via Internet on the Enviro$en$e World
Wide Web at www.epa.gov/oeca/sector.   Enviro$en$e is a free, public,  environmental exchange
system operated by EP As Office of Enforcement and Compliance Assurance and Office of Research
and Development. The Network allows regulators, the regulated community, technical experts, and
the general public to share information regarding: pollution prevention and innovative technologies;
environmental enforcement and compliance assistance; laws, executive orders, regulations, and
policies; points of contact for services and equipment; and other related topics.  The Network
welcomes receipt of environmental messages, information, and data from any public or private
person or organization.  Direct technical questions to the "Feedback" button on the bottom of the
web page.

Purchase printed bound copies from the Government Printing Office (GPO) by consulting the
order form at the back of this document or order via the Internet by visiting the on-line GPO Sales
Product Catalog at https://orders.access.gpo.gov/su_docs/sale/prf/prf.html. Search using the exact
title of the document "Profile of the XXXX Industry" or simply "Sector Notebook." When ordering,
use the GPO document number found in the order form at the back of this document.

Complimentary volumes are available to  certain groups or subscribers, including public and
academic libraries; federal, state, tribal, and local governments; and the media from EP A's National
Service Center for Environmental Publications at (800) 490-9198.  When ordering, use the EPA
publication number found on the following page.

The Sector Notebooks were developed by the EPA's Office of Compliance. Direct general questions
about the Sector Notebook Project to:

      Seth Heminway, Coordinator, Sector Notebook Project
      US EPA Office of Compliance
       1200 Pennsylvania Avenue, NW (2223-A)
      Washington, DC 20460
      (202) 564-7017

For further information, and for answers to questions pertaining to these documents, please refer to
the contact names listed on the following page.
Sector Notebook Project
        September 2000

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Agricultural Chemical Industry
                                                              Sector Notebook Project
                        SECTOR NOTEBOOK CONTACTS

Questions and comments regarding the individual documents should be directed to the specialists listed
below. See the Notebook web page at: www.epa.gov/oeca/secior for the most recent titles and staff
contacts.
EPA Publication
     Number
EPA/310-R-95-001.
EPA/310-R-95-002.
EPA/310-R-95-003.
EPA/310-R-95-004.
EPA/310-R-95-005.
EPA/310-R-95-006.
EPA/310-R-95-007.
EPA/310-R-95-008.
EPA/310-R-95-009.
EPA/310-R-95-010.
EPA/310-R-95-011.
EPA/310-R-95-012.
EPA/310-R-95-013.
EPA/310-R-95-014.
EPA/310-R-95-015.
EPA/310-R-95-016.
EPA/310-R-95-017.
EPA/310-R-95-018.
EPA/310-R-97-001.
EPA/310-R-97-002.
EPA/310-R-97-003.
EPA/310-R-97-004.
EPA/310-R-97-005.
EPA/310-R-97-006,
EPA/310-R-97-007.
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
R-97-008.
R-97-009.
•R-98-001.
•R-97-010.
•R-99-006.
•R-00-003.
EPA/310-R-OO-OOl
EPA/310-R-00-002
             Industry
Profile of the Dry Cleaning Industry
Profile of the Electronics and Computer Industry*
Profile of the Wood Furniture and Fixtures Industry
Profile of the Inorganic Chemical Industry*
Profile of the Iron and Steel Industry
Profile of the Lumber and Wood Products Industry
Profile of the Fabricated Metal Products Industry*
Profile of the Metal Mining Industry
Profile of the Motor Vehicle Assembly Industry
Profile of the Nonferrous Metals Industry
Profile of the Non-Fuel, Non-Metal Mining Industry
Profile of the Organic Chemical Industry  *
Profile of the Petroleum Refining Industry
Profile of the Printing Industry
Profile of the Pulp and Paper Industry
Profile of the Rubber and Plastic industry
Profile of the Stone, Clay, Glass, and Concrete Ind.
Profile of the Transportation Equip. Cleaning Ind.
Profile of the Air Transportation Industry
Profile of the Ground Transportation Industry
Profile of the Water Transportation Industry
Profile of the Metal Casting Industry
Profile of the Pharmaceuticals Industry
Profile of the Plastic Resin and Man-made Fiber Ind.
Profile of the Fossil Fuel Electric Power Generation
      Industry
Profile of the Shipbuilding and Repair Industry
Profile of the Textile Industry
Profile of the Aerospace Industry
Sector Notebook Data Refresh-1997 **
Profile of the Oil and Gas Extraction Industry
Profile of the Agricultural Chemical, Pesticide, and
      Fertilizer Industry
Profile of the Agricultural Crop Production Industry
Profile of the Agricultural Livestock Production
      Industry
Contact Phone (202)
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Maria Malave
Anthony Raia
Debbie Thomas
Rob Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Seth Heminway

Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Steve Hoover
Emily Chow
Sally Sasnett
Rafael Sanchez
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-5027
564-6045
564-5041
564-2628
564-7067
564-7003
564-7072
564-7017
564-2310
564-7013
564-7057
564-7057
564-7057
564-7057
564-7007
564-7071
564-7074
564-7028
Anthony Raia

Anthony Raia
Seth Heminway
Dan Chadwick
Michelle Yaras

Ginah Mortensen
Ginah Mortensen
  564-6045
  564-2310
  564-6045
  564-7017
  564-7054
  564-4153

913-551-5211
913-551-5211
EPA/310-R-99-001.
                           Government Series
            Profile of Local Government Operations
                                                                 564-2310
*   Spanish translations available.
**  This document revises compliance, enforcement, and toxic release inventory data for all profiles published in
    1995.
 Sector Notebook Project
                                        11
                                                            September 2000

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Agricultural Chemical Industry
                    Sector Notebook Project
                            TABLE OF CONTENTS

LIST OF FIGURES	v

LIST OF TABLES .	 vi

LIST OF ACRONYMS	viii

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	 1
      LA.  Summary of the Sector Notebook Project	-	.1
      I.B.  Additional Information	. 2 '

II. INTRODUCTION TO THE AGRICULTURAL CHEMICAL INDUSTRY		3
      II. A. Introduction, Background, and Scope of the Notebook	3
      II.B. Characterization of the Fertilizer, Pesticide, and Agricultural Chemical Industry  .. 4
             II.B.l.  Product Characterization	5
             II.B.2.  Industry Size and Geographic Distribution	 19
             II.B.3.  Economic Trends	 24

III.  INDUSTRIAL PROCESS DESCRIPTION	.27
      III.A. Nitrogenous Fertilizers	27
             III.A.l. Synthetic Ammonia	27
             III.A.2. Nitric Acid	32
             III.A.3. Ammonium Nitrate and Urea	 36
      III.B. Phosphatic Fertilizers	40
             III.B.l. Phosphoric Acid (Wet Process)	40
             III.B.2. Ammonium Phosphate	 43
             III.B.3. Normal Superphosphate	 44
             III.B.4. Triple Superphosphate	 47
      III.C. Fertilizer Mixing	49
      III.D. Pesticide Formulating and Preparing Processes .	.51
             III.D.l. Liquid Formulating and Packaging	52
             III.D.2. Dry Formulating and Packaging	5-3
             III.D.3. Aerosol Packaging	55
             III.D.4. Pressurized Gas Formulating and Packaging	 56
             III.D.5. Repackaging	56
      III.E. Raw Material Inputs and Pollution Outputs	57
             III.E.l. Fertilizers	57
             III.E.2. Pesticide Formulating, Packaging, and Repackaging	66
      III.F. Management of Chemicals in Wastestream	71
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Agricultural Chemical Industry
                    Sector Notebook Project
IV. CHEMICAL RELEASE AND TRANSFER PROFILE	75
      IV.A. EPA Toxic Release Inventory for the Fertilizer, Pesticide, and Agricultural
             Chemical Industry	.-	78
      IV.B. Summary of Selected Chemicals Released	92
      IV.C. Other Data Sources	..96
      IV.D. Comparison of Toxic Release Inventory Between Selected Industries	 98

V. POLLUTION PREVENTION OPPORTUNITIES  .	.101
      V.A. Equipment Cleaning	 105
      V.B. Process Changes	109
      V.C. Good Housekeeping	Ill

VI. Summary of Applicable Federal Statutes and Regulations	117
      VI.A. General Description of Major Statutes	 117
            Imports and Exports	119
      VLB. Industry Specific Requirements	135
      VI.C. State Requirements	 144
      VI.D. Pending and Proposed Regulatory Requirements	145

VII. COMPLIANCE AND ENFORCEMENT HISTORY	149
      VILA.  Fertilizer, Pesticide, and Agricultural Chemical Industry Compliance History  153
      VII.B.  Comparison of Enforcement Activity Between Selected Industries ......... 155
      VII.C.  Review of Major Legal Actions	 160
            VII.C.l.  Review of Major Cases	160
            VII.C.2.  Supplementary Environmental Projects (SEPs)		164

VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES	165
      VIII.A. Sector-Related Environmental Programs and Activities	165
      VIII.B. EPA Voluntary Programs	167
      VIII.C. Trade Association/Industry Sponsored Activity	173
            VIII.C.1. Trade Associations	173

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS 	181
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Agricultural Chemical Industry
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                                LIST OF FIGURES

Figure 1:   Number of Facilities and Value of Shipments of the Fertilizer, Pesticide, and
           Agricultural Chemical Manufacturing Industry	6
Figure 2:   Product Distribution for SIC 2873, Nitrogenous Fertilizers	9
Figure 3:   Product Distribution for SIC 2874, Phosphorous Fertilizers	11
Figure 4:   Product Distribution for SIC 2879, Pesticides and Miscellaneous Agricultural
           Chemicals	16
Figure 5:   Geographic Distribution of the Fertilizer Industry (SIC 2873, 2874, 2875)  	20
Figure 6:   Geographic Distribution of the Pesticide Formulating and Miscellaneous
           Agrichemical Formulating Facilities (SIC 2879)	22
Figure 7:   Typical Process of Ammonia Synthesis	29
Figure 8:   Typical Process of Dual-Stage, Weak Nitric Acid Production	35
Figure 9:   Typical Process Diagram of High Strength Nitric Acid Production	 36
Figure 10:  Typical Process for Ammonium Nitrate and Urea Manufacturing	39
Figure 11:  Typical Process of a Wet Process Dihydrate Phosphoric Acid Plant	42
Figure 12:  Typical Vacuum Evaporator Process	42
Figure 13:  Simplified Process Flow Diagram of Diammnonium Phosphate Production  	44
Figure 14:  Typical Process for Normal Superphosphate Manufacturing ......	46
Figure 15:  Typical Process for Triple Superphosphate	:	.48
Figure 16:  Typical Process for Liquid Formulating	53
Figure 17:  Typical Process for Dry Formulating	55
Figure 18:  Raw Material Flowchart for Principal Fertilizer Materials	57
Figure 19:  Summary of 1995 TRI Releases and Transfers by Industry	99
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         September 2000

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Agricultural Chemical Industry
                     Sector Notebook Project
                                 LIST OF TABLES

Table 1:    Nitrogenous Fertilizer Products (SIC 2873)	7
Table 2:    Phosphatic Fertilizer Products (SIC 2874)	9
Table 3:    1990 Direct vs Mixed Application of Primary Fertilizer Nutrients	12
Table 4:    SIC 2879 Pesticides and Miscellaneous Agricultural Chemicals, List of Products  13
Table 5:    Establishment Counts Based on Product Type	18
Table 6:    Facility Size Distribution for the Fertilizer, Pesticide, and Agricultural Chemical
           Manufacturing Industry	19
Table 7:    States with the Largest Number of Fertilizer Manufacturing Facilities	21
Table 8:    Top United States Agricultural Chemical Companies	23
Table 9:    Fertilizer Materials Used in Bulk Blends	49
Table 10:   Approximate Quantities of Most Commonly Used Conventional Pesticides in United
           States Agricultural Crop Production	 67
Table 11-:   Summary of Potential Pollution Outputs for the Agricultural Chemical Industry .. 70
Table 12:   Source Reduction and Recycling Activity for the Fertilizer Industry as Reported
           within TRI	72
Table 13:   Source Reduction and Recycling Activity for the Pesticide and Miscellaneous
           Agricultural Chemicals Industry  	73
Table 14:   1996 TRI Releases for Agricultural Chemicals Facilities (SICs 2873,2874,2875)
           by Number of Facilities Reporting (Releases reported in pounds/year)	81
Table 15:   1996 TRI Transfers for Agricultural Chemicals Facilities (SICs 2873,2874,2875)
           by Number and Facilities Reporting (Transfers reported in pounds/year)	82
Table 16:   1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of
           Facilities Reporting (Releases reported in pounds/year)  	83
Table 17:   1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)
           by Number and Facilities Reporting (Transfers reported in pounds/year)	86
Table 18:   Top 10 TRI Releasing Fertilizer Manufacturing and Mixing Facilities
           (SIC 2873, 2874, 2875) 	90
Table 19:   Top 10 TRI Releasing Facilities Reporting Fertilizer Manufacturing and Mixing SIC
           Codes	90
Table 20:   Top 10 TRI Releasing Pesticide and Miscellaneous Agricultural Chemicals Facilities
           (SIC2879)	91
Table 21:   Top 10 TRI Releasing Facilities Reporting Pesticide and Miscellaneous Agricultural
           Chemicals SIC Codes	91
Table 22:   Air Pollutant Releases by Industry Sector (tons/year)	 97
Table 23:   1995 Toxics Release Inventory Data for Selected Industries	100
Table 24:   Waste Minimization Methods for the Fertilizer, Pesticide, and Agricultural Chemical
           Industry	104
Table 25:   Five-Year Enforcement and Compliance Summary for the Fertilizer, Pesticide, and
           Agricultural Chemical Industry 	154
Table 26:   Five-Year Enforcement and Compliance Summary for Selected Industries	156
Table 27:   One-Year Enforcement and Compliance Summary for Selected Industries  	157
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Agricultural Ghemical Industry
                     Sector Notebook Project
Table 28:   Five-Year Inspection and Enforcement Summary by Statute for
           Selected Industries	158
Table 29:   One-Year Inspection and Enforcement Summary by Statute for
           Selected Industries	159
Table 30:   Fertilizer, Pesticide, and Agricultural Ghemical Industry Participation in the 33/50
           Program	'.	169
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Agricultural Chemical  Industry
                     Sector Notebook Project
                             LIST OF ACRONYMS

AAEA    American Agricultural Economics Association
AAPCO   Association of American Pesticide Control Officials
AAPFCO  Association of American Plant Food Control Officials
ACPA    American Crop Protection Association
AFS      AIRS Facility Subsystem (CAA database)
AI        Active Ingredient
AIRS     Aerometric Information Retrieval System (CAA database)
ASA      American Society of Agronomy
BIFs      Boilers and Industrial Furnaces (RCRA)
BOD      Biochemical Oxygen Demand
CAA      Clean Air Act
CAAA    Clean Air Act Amendments of 1990
CERCLA  Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS  CERCLA Information System
CFA      California Fertilizer Association
CFCs     Chlorofluorocarbons
CMA     Chemical Manufacturers Association
CO       Carbon Monoxide
COD      Chemical Oxygen Demand
CSI       Common Sense Initiative
CSMA    Chemical Specialties Manufacturers Association
CWA     Clean Water Act
DAP      Diammonium Phosphate
DOT      Department of Transportation
D&B      Dun and Bradstreet Marketing Index
EPA      United States Environmental Protection Agency
EPCRA   Emergency Planning and Community Right-to-Know Act
FFDCA   Federal Food,  Drug, and Cosmetic Act
FIFRA    Federal Insecticide, Fungicide, and Rodenticide Act
FINDS    Facility Indexing System
FIRT      Fertilizer Industry Round Table
FQPA     Food Quality Protection Act
HAPs     Hazardous Air Pollutants (CAA)
HSDB     Hazardous Substances Data Bank
IDEA     Integrated Data for Enforcement Analysis
IFDC      International Fertilizer Development Center
LDR      Land Disposal Restrictions (RCRA)
LEPCs    Local Emergency Planning Committees
MACT    Maximum Achievable Control Technology (CAA)
MAP      Monoammonium Phosphate
MCLGs   Maximum Contaminant Level Goals
MCLs     Maximum Contaminant Levels
MEA      Monoethanolamine
Sector Notebook Project
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September 2000

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Agricultural Chemical Industry
                    Sector Notebook Project
MEK      Methyl Ethyl Ketone
MSDSs    Material Safety Data Sheets
NACD     National Association of Chemical Distributors
NASD A   National Association of State Departments of Agriculture
NASHA   North American Horticultural Supply Association
NCDB     National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP       National Oil and Hazardous Substances Pollution Contingency Plan
NEC       Not Elsewhere Classified
NEIC      National Enforcement Investigation Center
NESHAP  National Emission Standards for Hazardous Air Pollutants
NO2       Nitrogen Dioxide
NOV      Notice of Violation
NOX       Nitrogen Oxide
NPCA     National Pest Control Association
NPDES    National Pollution Discharge Elimination System (CWA)
NPK       Nitrogen-Phosphorous-Potassium
NPL       National Priorities.List
NRC       National Response Center
'NRDC     National Resources Defense Council
NSP       Normal Superphosphate
NSPS      New Source Performance Standards (CAA)
OECA     Office of Enforcement and Compliance Assurance
OMB      Office of Management and Budget
OPA       Oil Pollution Act
OPPTS    Office of Prevention, Pesticides, and Toxic Substances
OSHA     Occupational Safety and Health Administration
OSW      Office of Solid Waste
OSWER   Office of Solid Waste and Emergency Response
OW       Office of Water
P2        Pollution Prevention
PCS       Permit Compliance System (CWA Database)
PRP       Potentially Responsible Party
POTW    Publicly Owned Treatments Works
PPI       Potash and Phosphate Institute
RCRA     Resource Conservation.and Recovery Act
RCRIS    RCRA Information System
SARA     Superfund Amendments and Reauthorization Act
SDWA    Safe Drinking Water Act
SEPs      Supplementary Environmental Projects
SERCs    State Emergency Response Commissions
SFIREG   State FIFRA- Issues Research and Evaluation Group
SIC       Standard Industrial Classification
SO2       Sulfur Dioxide
 SOX       Sulfur Oxides
TOC      Total Organic Carbon
TFI       The Fertilizer Institute
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Agricultural Chemical Industry
Sector Notebook Project
TRI       Toxic Release Inventory
TRIS      Toxic Release Inventory System
TCRIS     Toxic Chemical Release Inventory System
TSCA     Toxic Substances Control Act
TSP       Triple Superphosphate
TSS       Total Suspended Solids
TVA      Tennessee Valley Authority
UIC       Underground Injection Control (SDWA)
UPFDA    United Products Formulators and Distributors Association
USDA     United States Department of Agriculture
UST       Underground Storage Tanks (RCRA)
VOCs     Volatile Organic Compounds
WCPA     Western Crop Protection Association
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       September 2000

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Agricultural Chemical Industry
                    Sector Notebook Project
L  INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

LA. Summary of the Sector Notebook Project

                     Integrated environmental policies based upon comprehensive analysis of air,
                     water and land pollution are a logical supplement to traditional single-media
                     approaches to environmental protection. Environmental regulatory agencies
                     are beginning to embrace comprehensive, multi-statute solutions to facility
                     permitting, enforcement and compliance assurance, education/outreach,
                     research, and regulatory development issues. The central concepts driving
                     the new policy direction are that pollutant releases to each environmental
                     medium  (air, water and land) affect each other, and that environmental
                     strategies must actively identify and address these inter-relationships by
                     designing policies for the "whole" facility. One way to achieve a whole
                     facility focus is  to- design environmental policies for similar industrial
                     facilities.  By doing so, environmental concerns that are common to the
                     manufacturing of similar products can be addressed in a comprehensive
                     manner.  Recognition of the need to develop the industrial "sector-based"
                     approach within the EPA Office of Compliance led to the creation of this
                     document.

                     The  Sector Notebook Project was originally initiated by the Office of
                     Compliance within the Office of Enforcement and Compliance Assurance
                     (OECA)  to provide its staff and managers with summary information for
                     eighteen specific industrial  sectors. As other EPA offices, states, the
                     regulated community,  environmental groups, and  the  public became
                     interested in this project, the scope of the original project was expanded to
                     its current form.  The  ability to design comprehensive, common sense
                     environmental protection measures for specific industries is dependent on
                     knowledge of several inter-related topics. For the purposes of this project,
                     the key elements chosen for inclusion are:  general industry information
                     (economic and geographic); a description of industrial processes; pollution
                     outputs; pollution prevention opportunities; federal statutory and regulatory
                     framework; compliance history; and a description of partnerships that have
                     been formed between regulatory agencies, the regulated community and the
                     public.                               -

                     For any given industry, each topic listed above could alone be the subject of
                     a lengthy volume. However, in order to produce a manageable document,
                     this proj ect focuses on providing summary information for each topic. This
                     format provides the reader with a synopsis of each issue, and references
                     where more in-depth information is available. Text within each profile was
                     researched from a variety of sources, and was usually condensed from more
                     detailed sources pertaining to specific topics.  This approach allows for a
                     wide coverage of activities that can be further explored based upon the
                     citations and references listed at the end of this profile. As a check on the
Sector Notebook Project
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Agricultural Chemical Industry
Sector Notebook Project
                     information included, each notebook went through an external review
                     process. The Office of Compliance appreciates the efforts of all those that
                     participated in this process who enabled us to develop more complete,
                     accurate and up-to-date summaries.  Many of those who reviewed this
                     notebook  are listed as contacts  in Section IX and may be sources  of
                     additional information.  The individuals  and groups on this list do not
                     necessarily concur with all statements within this notebook.

I.B.  Additional Information
Providing Comments
                     OECA's Office of Compliance plans to periodically review and update the
                     notebooks and will make these updates available both in hard copy and
                     electronically. If you have any comments on the existing notebook, or if you
                     would like to provide additional information, please send a hard copy and
                     computer disk to the EPA Office of Compliance, Sector Notebook Project
                     (2223-A), 1200  Pennsylvania Avenue,  NW, Washington,  DC 20460.
                     Comments can also be uploaded to the Enviro$en$e World Wide Web for
                     general access to all users of the system. Follow instructions in Appendix
                     A for accessing this  system.  Once you have logged in, procedures for
                     uploading text are available from the on-line Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
                     The scope of the industry sector described in this notebook approximates
                     the national occurrence of facility  types within the sector.   In  many
                     instances, industries within specific geographic regions or states may have
                     unique characteristics that are not fully captured in these profiles.  The
                     Office of Compliance encourages state and local environmental agencies and
                     other groups to supplement or repackage the information included in this
                     notebook to include more specific industrial and regulatory information that
                     may be available. Additionally, interested states may want to supplement
                     the "Summary of Applicable Federal Statutes and Regulations" section with
                   '  state and local requirements. Compliance or technical assistance providers
                     may also want to develop the "Pollution Prevention" section in more detail.
                     Please contact the appropriate specialist listed on the opening page of this
                     notebook  if your office  is interested in assisting  us in the further
                     development of the information or policies addressed within this volume.
                     If you are interested in assisting in the development of new notebooks for
                     sectors not covered in the original eighteen, please contact the Office of
                     Compliance at 202-564-2310.
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        September 2000

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Agricultural Chemical Industry	___	Introduction and Scope

II. INTRODUCTION TO THE AGRICULTURAL CHEMICAL INDUSTRY

                     This section provides  background information on the size,  geographic
                     distribution, employment, production, sales, and economic condition of the
                     fertilizer, pesticide, and agricultural chemical industry. Facilities described
                     within this document are described in terms of their Standard Industrial
                     Classification (SIC) codes whenever possible.

II.A.  Introduction, Background, and Scope of the Notebook

                    The scope of this Sector Notebook covers the manufacturing and production
                    of fertilizers, the formulation of pesticide chemicals (both agricultural and
                    non-agricultural) manufactured at separate facilities, and the production of
                    other miscellaneous agricultural chemicals. It does not include the use, sale,
                    distribution, or storage of such chemicals.

                    The Fertilizer, Pesticide, and Agricultural Chemical Industry is classified by
                    the Office  of Management and Budget (OMB) under Standard Industrial
                    Classification (SIC)  Industry  Group  Number 287.  This  classification
                    corresponds to SIC codes which were established by the OMB to track the
                    flow of goods and services within the economy. Industry Group Number 287
                    includes SIC codes:

                           2873— Nitrogenous Fertilizers
                           2874- Phosphatic Fertilizers
                           2875- Fertilizers, Mixing Only
                           2879— Pesticides and Agricultural Chemicals, Not Elsewhere
                           Classified (n.e.c)

                    This  notebook  covers   both  fertilizer  manufacturing  and formulating
                    operations  including ammonia synthesis,  nitric and  phosphoric  acid
                    production, and the mixing, preparing, and packaging of nitrogenous and
                    phosphatic fertilizers. Establishments engaged  in manufacturing fertilizer
                    materials or  mixing fertilizers produced  at the same establishment are
                    classified under SIC codes 2873 and 2874. Mixing of fertilizer materials,
                    such  as compost,  potting  soil,  and  fertilizers made  in plants  not
                    manufacturing fertilizer materials, is classified under SIC code 2875. This
                    notebook does not include the mining or grinding of phosphate rock, which
                    is classified under SIC code 1475, and it also does not include the use  or
                    application of fertilizers.

                    SIC code 2879, pesticides and agricultural chemicals not elsewhere classified
                    (n.e.c.), hereafter referred to as pesticides and  miscellaneous agricultural
                    chemicals, covers only the formulating, preparing, and packaging of ready-to-
                    use agricultural and household pest control chemicals. This industry code
                    also includes  establishments primarily engaged in the  manufacturing  or

Sector Notebook Project                      3                             September 2000

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Agricultural Chemical Industry
                      Introduction and Scope
                     formulating of agricultural chemicals, not elsewhere classified, such as minor
                     or trace elements and soil conditioners.  This notebook does not discuss the
                    , use or application of pesticide products. Establishments primarily engaged
                     in the manufacturing of basic or technical agricultural pesticides are classified
                     in Industry Group 281 if the chemicals produced are inorganic or Industry
                     Group 286 if the chemicals produced are organic. This notebook also does
                     not cover the agricultural supply sector, SIC 5191, which is engaged in the
                     wholesale and  distribution of various  agricultural  supplies  including
                     fertilizers and pesticides. Also, there is little discussion of the potassium
                     fertilizer  industry as   potash  is classified under SIC 2819,  Inorganic
                     Chemicals n.e.c.

                     Federal government agencies, including United States EPA, are beginning to
                     implement an industrial classification system developed by OMB to replace
                     the SIC code system. The new system, which is based on similar production
                     processes, is called the North American Industrial Classification  System
                     (NAICS). In the NAIC system, the manufacturing of nitrogenous fertilizers
                     (SIC 2873) is classified as NAIC 325311, phosphatic fertilizers (SIC 2874)
                     as NAIC 325312, and fertilizer mixing only (SIC 2875) as NAIC 325314.
                     Pesticide  formulating and agricultural chemicals n.e.c.  (SIC 2879)  is
                     classified under NAIC 32532. Because EPA databases, and other databases
                     used in this document, are  still  using the SIC system, the industry sectors
                     described in this Sector Notebook are described in terms of their SIC codes.

II.B.  Characterization of the Fertilizer, Pesticide, and Agricultural Chemical Industry

                     As the world population increases, crop lands are unable to meet the growing
                     demand for food without employing some method of crop enhancement.
                     There are five common practices used to meet the growing demand:

                     •   increasing tilled acreage
                     •   improving plant strains
                     •   introducing or expanding irrigation
                     •   controlling pest by chemical or biological methods
                     •   initiating or increasing fertilizer usage

                     Increased utilization of the last two methods has created a large agrichemical
                     industry which produces a wide variety of products designed to increase crop
                     production and protect crops from disease and pests (Kent, 1992). Together,
                     the production of fertilizers and the formulation of pesticides was  a $18.8
                     billion industry in 1992, employing over 40,000  people (USDOC, 1995).

                     Plants require 18 elements to grow, the most important being oxygen, carbon,
                     hydrogen, nitrogen, phosphorous, and potassium. Oxygen,  carbon, and
                     hydrogen are obtained from the atmosphere and water, while nitrogen,
                     phosphorous,  and potassium are naturally obtained from soil. However,
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                      under current high yield production methods, soils are stripped  of the
                      essential nutrients, requiring the addition of fertilizers (primarily consisting
                      of nitrogen, phosphorous,  and potassium) to resupply  the  land.   The
                      additional 12 essential nutrients are generally maintained in soil at sufficient
                      levels for plant growth, but they may be added to some fertilizers  (Kent
                      1992).

                      Even before the addition of nutrients to farm lands, farmers were forced to
                      protect their crops against pests with chemicals.  References to pesticide
                      usage date back to 1000 B.C.  Pests are continuously adapting to pesticide
                      chemicals  requiring new pesticides  and the usage  of multiple chemical
                      agents. The industry is rapidly changing due to biological adaptation of pests,
                      laboratory discoveries,  and government  regulation (Kent, 1992).   The
                      pesticide industry is  faced with the need for new formulations and the
                      abundance of possible combinations, but  restricted by cost factors and a
                      sometimes lengthy registration process.

                      Pesticides are.applied on about three-quarters of United States farms and
                      households. Farmers' expenditures on pesticides were equal to 4.6 percent
                      of total farm production expenditures in 1995, up from 3.9 percent in 1993.
                      About one billion pounds of active ingredient of conventional pesticides are
                      used annually in the United States; this usage involves about 21,000 pesticide
                      products (including non-agricultural products) and 875 active  ingredients
                      registered under the Federal Pesticide Law, according to the 1994 and 1995
                     Market Estimates for Pesticides Industry Sales and Usage (Aspelin, 1997).

       II.B.l.  Product Characterization

                     This 'notebook covers all aspects  of fertilizer  production and pesticide
                     formulating and packaging. However, because the  industrial processes,
                     pollutant outputs, economics, size, and geographic distribution of the two
                     industries are  different,  they  are  dealt with separately  throughout  the
                     notebook.

                     Figure 1 compares the number of manufacturing facilities and value  of
                     shipments for each of the major sectors within the Fertilizer, Pesticide, and
                     Agricultural Chemical Industry, as reported by the United States Bureau of
                     Census. The figure shows that the fertilizer mixing industry has the largest
                     number of facilities but the smallest value of shipments. This reflects that,
                     compared to other sub-sectors within the Fertilizer, Pesticide and Agricultural
                     Chemical Industry, these facilities  produce a relatively small  volume  of
                     product and sell  a relatively  low  value  product.   Phosphatic fertilizer
                     producers,,on the other hand, comprise the smallest number  of facilities but
                     have a relatively large share of the industry's value of shipments, reflecting
                     that individual facilities produce a relatively large volume of product.
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                 Figure 1:  Number of Facilities and Value of Shipments of the Fertilizer,
                 Pesticide, and Agricultural Chemical Manufacturing Industry
                        (number of manufacturing facilities)         (millions of dollars)

                                      75                    $4,049.4 ^^^^
                                                                               $3,588.4
                       401
                                            152
$1,781.5
                                         263
                                                                        $8,234.8
                                        Nitrogenous Fertilizers
                                        Phosphatic Fertilizers
                                        Fertilizers, Mixing only
                                        Pesticides and Ag. Chem. N.E.C.
                 Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, United States
                 Department of Commerce, Bureau of the Census, May 1995.
                 * United States EPA has identified over 8,000 establishments that could fall -within this SIC code
                 as it is defined by the OMB. See discussion in text below.
                     The Census of Manufacturers reports 263 establishments that can be defined
                     as producing pesticides and miscellaneous agricultural chemicals. These
                     establishments reportedly account for almost half of the value of shipments
                     for the sector. There are over 8,000 establishments identified by the United
                     States EPA that manufacture, formulate and package pesticides and other
                     agricultural chemicals and that could fall within OMB's SIC code definition
                     for this sector. Many of these are small establishments  and establishments
                     that have a primary line of business other than producing pesticides and other
                     miscellaneous agricultural chemicals. The Census only counts those facilities
                     which report an SIC code as their primary line of business, thus the number
                     of facilities shown above is not  inclusive of all facilities involved in
                     agricultural chemical production. Under the "Pesticides and Miscellaneous
                     Agricultural  Chemicals"  heading later  in this section, other pesticide
                     producing establishment counts are presented based on EPA estimates and
                     reporting under section  7 of the Federal  Insecticide,  Fungicide,  and
                     Rodenticide Act.
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                     Nitrogenous Fertilizers

                     The nitrogenous fertilizer industry includes  the  production of synthetic
                     ammonia, nitric acid, ammonium nitrate, and urea. Synthetic ammonia and
                     nitric acid, however, are used primarily as intermediates in the production of
                     ammonium nitrate and  urea fertilizers.  Table 1  lists  specific products
                     classified as nitrogenous fertilizers by OMB.
                        Table 1: Nitrogenous Fertilizer Products
                        (SIC 2873)	
                        Ammonia liquor
                        Ammonium nitrate
                        Ammonium sulfate
                        Anhydrous ammonia
                        Aqua ammonia
                        Fertilizers, mixed, produced in nitrogenous fertilizer plants
                        Fertilizers, natural
                        Nitric acid
                        Nitrogen fertilizer solutions
                        Plant foods, mixed in nitrogenous fertilizer plants
                        Urea
                        Source: Standard Industrial Classification Manual, Office of
                        Management and Budget, 198 7.	
                     Synthetic Ammonia
                     Synthetic ammonia refers to ammonia that has been synthesized from natural
                     gas.  In this process, natural gas molecules are reduced to carbon and
                     hydrogen.  The hydrogen is then purified and reacted with nitrogen to
                     produce ammonia. Approximately 75 percent of the synthetic  ammonia
                     produced in the United States is used as fertilizer, either directly as ammonia
                     or indirectly after fertilizer synthesis into urea, ammonium nitrate, and
                     monoammonium or diammonium phosphates.  One-third  of the fertilizer
                     nitrogen is applied directly to the land as anhydrous ammonia. The remaining
                     25 percent of ammonia produced in the United States is used as raw material
                     in the manufacture of polymeric resins, explosives, nitric acid, and other
                     products (USEPA, 1993a).

                     Nitric Acid
                     Nitric acid is formed by  concentration, absorption, and oxidation  of
                     anhydrous ammonia.   About 70 percent of the nitric acid produced is
                     consumed as an intermediate in the  manufacture of ammonium nitrate
                     (NH4NO3), which is primarily used in fertilizers. Another 5 to 10 percent of
                     the nitric acid produced is used in adipic acid manufacturing, an intermediate
                     in nylon production. Explosive manufacturing utilizes nitric acid for organic
                     nitrations to produce nitrobenzene, dinitrotoluenes,  and  other  chemical
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                     intermediates. Other end uses of nitric acid are gold and silver separation,
                     military munitions, steel and brass pickling, photoengraving, and acidulation
                     of phosphate rock (USEPA, 1993a).

                     Ammonium Nitrate
                     Ammoniurn nitrate is produced by neutralizing nitric acid with ammonia.
                     Approximately 15 to 20 percent of ammonium nitrate is used for explosives
                     and the balance for fertilizer. Ammonium nitrate is marketed in several
                     forms, depending upon its use. Liquid ammonium nitrate may be sold as a
                     fertilizer, generally in combination with urea. Liquid ammonium nitrate may
                     also be concentrated to form an ammonium nitrate "melt" for use in solids
                     formation processes. Solid ammonium nitrate may be produced in the form
                     of prills, grains,  granules  or crystals.  Prills,  round or  needle-shaped
                     aggregates, can be produced in either high or low density form, depending on
                     the concentration of the melt. High density prills, granules and crystals are
                     used as fertilizer, grains are used solely in explosives, and low density prills
                     can be used as either fertilizer or explosives (USEPA, 1993a).

                     Urea
                     Urea, also known as carbamide or carbonyl diamide, is produced by reacting
                     ammonia with carbon dioxide. Eighty-five percent of urea solution produced
                     is used in fertilizer mixtures, with  three percent going to animal feed
                     supplements and  12 percent is used for plastics and other uses. Urea is
                     marketed as a solution or in solid form. Most solids are produced as prills or
                     granules for use as fertilizer or protein supplement in animal feed, and in,
                     plastics manufacturing (USEPA,  1993a).

                     Ammonium sulfate
                     It is not economically feasible to produce ammonium sulfate for use as  a
                     fertilizer. However, ammonium sulfate is formed as a by-product of other
                     process such as acid scrubbing of coke oven gas, synthetic fiber production,
                     and the ammoniation of process sulfuric acid (Hoffmeister, 1993). Therefore,
                     the production of ammonium sulfate is not described in this notebook.
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         Figure 2:  Product Distribution for SIC 2873, Nitrogenous Fertilizers
                                           1996 Production
                                           (in thousands of tons)
                                           16,814
                                         3,060
                                  Ammonia
                                  Urea
                                                                2,605
   5,551

I  I   Ammonium nitrate
•   Ammonium sulfate
            Source: Fertilizer Institute data as reported in Chemical and Engineering News, June 23, 1998. Figures
            are based on Fertilizer Institute surveys and may not represent the entire industry.
                      Phosphatic Fertilizers

                      The phosphatic fertilizer industry can be divided into three major segments:
                      phosphoric acid, granular ammonium phosphate, and normal and triple
                      superphosphate.  Table 2 lists these, and a few additional, less common
                      products classified as phosphatic fertilizers by OMB.
                           Table 2:  Phosphatic Fertilizer
                           Products (SIC 2874)	
                           Ammonium phosphates
                           Calcium meta-phosphates
                           Defluorinated phosphates
                           Diammonium phosphates
                           Fertilizers, mixed, produced in phosphatic fertilizer
                           plants
                           Phosphoric acid
                           Plant foods, mixed in phosphatic fertilizer plants
                           Superphosphates, amtnoniated and not ammoniated
                           Source: Standard Industrial Classification Manual, Office of
                           Management and Budget, 1987.	
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                    Phosphoric Acid
                    Phosphoric acid (H3PO4) can be manufactured using either a wet or a thermal
                    process to react phosphate rock with sulfuric acid. Approximately 96 percent
                    of the phosphoric acid produced in the United States is produced using the
                    wet process. Wet process phosphoric acid has a phosphorous concentration
                    typically ranging from 26-30% as phosphorous pentoxide (P2O5) and is used
                    in the  production of ammonium phosphates and  triple superphosphates.
                    Thermal process phosphoric acid is commonly used in the manufacture of
                    high grade chemicals requiring a much higher purity.

                    Ammonium Phosphates
                    Ammonium phosphate (NH4H2PO4) is produced by reacting phosphoric acid
                    with anhydrous ammonia. Both solid and  liquid  ammonium phosphatic
                    fertilizers are produced in the United States The most common ammonium
                    phosphatic  fertilizer grades are monoammonium  phosphate (MAP) and
                    diammonium phosphate (DAP). DAP has become one of the most commonly
                    used fertilizers because it provides a  large quantity  of  plant food, is
                    compatible with most mix fertilizer ingredients, and is nonexplosive. It may
                    be directly applied or used in irrigation systems as it is completely soluble in
                    water.  DAP is also preferred over MAP because it is capable of fixing twice
                    as much ammonia per phosphorous pentoxide in solid form (Nielson, 1987.)
                    MAP contains a higher concentration of phosphorous pentoxide than DAP.
                    It is favored for use with alkaline soils and may be applied either directly or
                    in a dry blend.

                    Normal Superphosphates
                    Like phosphoric acid, normal, or "ordinary," superphosphate fertilizers are
                    produced by reacting phosphate rock with sulfuric  acid.  However, normal
                    superphosphate (NSP) retains calcium sulfate which forms by the reaction
                    between phosphate rock and sulfuric acid.  For this reason NSP  retains its
                    importance wherever sulphur deficiency limits crop yields (UNEP, 1996).
                    NSP refers to fertilizer material containing 15 to 21 percent phosphorous as
                    phosphorous  pentoxide (P2O5). As defined by the Census Bureau, NSP
                    contains not  more than 22 percent  of  available P2O5  (USEPA, 1993a).
                    Production  of NSP  has  given  way to  the   higher-yielding  triple
                    superphosphates and ammonium phosphates. In 1990, production of NSP
                    accounted for only one  percent by weight of the phosphorous fertilizer
                    industry.   Because  of  its low P2O5  concentration,  shipping can  be
                    prohibitively expensive due to the large volumes required. NSP is favored
                    in low cost Nitrogen-Phosphorous-Potassium (NPK) mixes because it is a
                    less expensive form of phosphorous, however, it is unacceptable for higher-
                    grade mixes (Kent, 1992).

                    Triple Superphosphates
                    Triple superphosphates (TSP) are produced by reacting ground phosphate
                    rock with phosphoric acid. Triple superphosphate is also known as double,
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                     treble, or concentrated superphosphate. The phosphorus content of triple
                     superphosphates is over 40  percent, measured as phosphorus pentoxide
                     (P2O5), which is its main advantage over other phosphatic fertilizers (USEPA,
                     1993a).  TSP began to be produced in large quantities when wet process
                     phosphoric acid production became available commercially. It is commonly
                     produced along with phosphoric acid near phosphate rock supplies. TSP may
                     be applied directly or as a bulk blend (Kent, 1992).

                   Figure 3; Product Distribution for SIC 2874, Phosphorous Fertilizers
                                               1996 Production
                                               (in thousands of tons)
                                                           12,511
                                           1,701
                                            15,575
                              Phosphoric acid
                              Diammonium phosphate
                                                                3,332
                Concentrated superphosphate
                Monoammonium phosphate
                     Source: Chemical and Engineer ing News, June 23, 1998. Figures are based on Fertilizer
                     Institute surveys and may not represent the entire industry.

                     Fertilizers, Mixing Only

                     A significant part of the fertilizer industry only purchases fertilizer materials
                     in bulk from fertilizer manufacturing facilities and mixes them to sell as a
                     fertilizer formulation.

                     Phosphorous is the single nutrient most likely to be applied in a fertilizer
                     mixture, as seen in Table 3.
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Table 3: 1990 Direct vs Mixed Application of
Primary Fertilizer Nutrients
Nutrient
Nitrogen
Phosphorous
Potassium
TOTAL
Method, % applied
Direct
80
8
65
61
Mixtures
20
92
35
39
Source: Hoffmeister, G., "Fertilizers, " Kirk-Othmer
Encyclopedia of Chemical Technology, V. 10, 1993.
                     Although the Bureau of the Census only counts 401 facilities reporting the
                     SIC code for fertilizer mixing (2875) in 1992, other sources estimated the
                     true number of fertilizer mixing facilities to be closer to five or six thousand
                     in 1984 (Adrilenas and Vroomen, 1990). About half of applied fertilizers are
                     bulk blends. Fertilizer mixing facilities generally serve a small area such as
                     farms within a ten to fifty mile radius. The processes involved are simple and
                     relatively little value is added to the  raw materials purchased by mixing
                     facilities. Nevertheless, there are many of these facilities and volume of
                     production results in a $ 1.8 billion industry (value of annual shipments). The
                     industrial process is simple and resembles that of the pesticide formulating
                     sector. A brief discussion of fertilizer mixing processes is included in this
                     notebook.

                     Pesticides and Miscellaneous Agricultural Chemicals

                     The pesticides and agricultural chemicals n.e.c. (referred to here as pesticides
                     and miscellaneous agricultural chemicals)  industry group  (SIC  2879)
                     formulates and prepares ready to use agricultural and household pesticides
                     and other agricultural chemicals.  The manufacture of pesticide  active
                     ingredients  is  classified under  either Industry Group 281 for inorganic
                     chemicals or 286 for organics which are not covered by this notebook. (See
                     Profile of the Inorganic Chemicals Industry and Profile of the  Organic
                     Chemicals Industry Sector Notebooks.)  In the United States, over  850
                     different pesticide formulations and preparations are produced. In  1995, 31
                     new active ingredients were registered in the United States (Aspelin,  1997).
                     Most of these pesticides can be classified as either insecticides, herbicides,
                     or fungicides, although many other minor classifications exist. Also included
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                     in this category are blends of fertilizers and pesticides produced at pesticide
                     formulating and mixing facilities. Table 4 lists the  pesticides and other
                     products included in SIC 2879.
Table 4: SIC 2879 Pesticides and Miscellaneous Agricultural
Chemicals, List of Products
Agricultural disinfectants
Agricultural pesticides
Arsenates and arsenites
Bordeaux mixture
Cattle dips and sheep dips
DDT
Defoliants
Fly sprays
Fungicides
Growth regulants
Herbicides
Insecticides, agricultural and
household
Lime-sulfur, dry and solution
Lindane, formulated
Moth repellants
Nicotine and salts
Paris green
Pesticides, household
Phytoactin
Plant hormones
Poison, household
Pyrethrin
Rodenticides
Rotenone
Soil conditioners
Sulfur dust
Thiocyanates
Trace elements
(agrichemical)
Xanthone
Source: Standard Industrial Classification Manual, Office of Management and Budget, 1987.
                     In 1995, 77 percent (by volume) of all pesticides were used for agriculture,
                     12 percent for industrial, commercial, or governmental lands or facilities, and
                     11  percent for homes  and gardens (Aspelin, 1997).    Non-agricultural
                     pesticides and miscellaneous agricultural chemicals are included in the data
                     presented for sales, production, waste management, and enforcement and
                     compliance. However, since they represent a relatively small part of the
                     industry and cover a wide range of chemicals and production processes, these
                     products are not covered in the Industrial Processes and Pollutant Outputs
                     sections of this document.

                     Herbicides
                     Herbicides (in both value and quantity) are the largest class of pesticides used
                     in the United States, as well as in the world.  This class of pesticides, which
                     accounts  for approximately fifty percent of the value of aggregate world
                     pesticide  usage, is used to destroy or control a wide variety of weeds and
                     other unwanted plants. Because of its demonstrated farm labor savings,
                     nearly all the agricultural land in the United States is currently being treated
                     with some type of herbicide. In recent years, approximately fifty percent of
                     total United States pesticide consumption (by value) was herbicides (USITC,
                     1994).

                     Insecticides
                     Insecticides are the second largest pesticide category (by value) used in the
                     United States and in the world. In the early 1990s, insecticides accounted for
                     approximately  twenty-nine percent  of the  total value of United States
                     pesticide  consumption.  Historically, the  category of synthetic  organic
                     insecticides has been divided into one of four major chemical groups:
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                           •  organochlorines (e.g., DDT and chlordane)
                           •  organophosphates (e.g., parathion and diazinon)
                           •  carbamates (e.g., carbaryl)
                        1   •  pyrethroids (e.g., natural and synthetic)

                    Several compounds, discovered during the 1950s, found widespread use in
                    agriculture because of their high toxicity to a variety of insects. However, the
                    qualities that made these chemicals so desirable also led to their eventual
                    removal from the market, as these products also proved harmful to humans
                    and to the environment. Spurred in part by increased environmental concern,
                    researchers developed a new series of less toxic synthetic compounds called
                    pyrethroids. These compounds are based on the natural pyrethroids, which
                    are found in such plants as the chrysanthemum (USITC, 1994).

                    Fungicides
                    In recent years, fungicides accounted for approximately ten percent of the
                    value of total United States  pesticide consumption. Fungicides are  used
                    today primarily to protect agricultural crops and seeds from various fungi;
                    farmers previously used inorganic products, such as elemental sulfur and
                    copper sulfate. Initially, synthetic products were commercially unsuccessful,
                    because of their high manufacturing costs. By the 1940s, however, newer,
                    less expensive products became commercially successful. Today, fungicides
                    are manufactured from a variety of chemical classes. Commercially, the most
                    important fungicides are halogenated compounds, the carbamates  and
                    dithiocarbamates, and organophosphates (USITC, 1994).

                    Other Pesticides
                    Although small in total quantity consumed, a number of other classes of
                    pesticide products are on the  market.   Some of these pesticides are not
                    covered by this Notebook.

                    •   Biological pesticides, also  known as biopesticides,  include   true
                        biological agents, living or reproduced biological entities such as viruses
                        or bacteria, and naturally occurring biochemicals such as plant growth
                        regulators, hormones, and  insect sexual attractants  (pheromones) that
                        function by modes of action other than  innate toxicity. At the end of
                        1998, there were  approximately 175  registered  biopesticide active
                        ingredients and 700 products. Generally, biological pesticides pose little
                        or no risk to human health or the environment.   Accordingly  EPA
                        generally requires much less data to register a biopesticide than to register
                        a conventional pesticide (USEPA,  1999).   To further facilitate the
                        •registration of biopesticides, in 1994, EPA established the Biopesticides
                        and Pollution Prevention Division in the Office of Pesticide Programs.

                    •   Plant growth regulators have been developed by many companies to
                        improve crop production.  Plant growth regulators are produced for a
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                        variety of purposes, including loosening ripened fruits for faster harvest;
                        controlling the size and firmness of fruits; and regulating the size of a
                        plant to increase branching. These products account for a small portion
                        of world and United States usage. Future development will probably be
                        directed toward selected crops for which the application of these specialty
                        products is found to be the most cost effective (USITC, 1994).

                     •   Sex attractants may be used to attract insects to traps or to confuse
                        specific male insects, making it difficult to locate females for mating.
                        Commercially available sexual attractants are synthetically produced
                        compounds. Insect growth regulators, such as juvenile growth hormones,
                        are synthetic compounds similar to the natural chemicals that regulate
                        insect growth.

                     •   Genetically modified plants are plants developed through the use of
                        biotechnology.  There are three types of plants that are relevant to pest
                        control: herbicide-tolerant plants (which can tolerate certain types of
                        herbicides), insect-resistant plants (which can withstand attacks by certain
                        insects), and virus- and other pest-resistant plants (which are immune to
                        some types of plant viruses and other plant  pests). As of September
                        1994, several  genetically modified plants had been commercialized and
                        had elicited optimism that genetically modified plants would become an
                        important new approach to controlling pests (USDA, 1995).

                     The environmental benefits of reduced use of chemical pesticides are also
                     significant. Environmental side effects of traditional pesticides include the
                     cost of providing  alternative sources of drinking water, increased treatment
                     costs for public and private  water systems,  lost boating and  swimming
                     opportunities, worker safety concerns, exposure to nearby residents, increased
                     exposures for  farm children,  possible loss  of biodiversity, pressure on
                     threatened and endangered species, and damage to recreational and fishery
                     resources (USDA, 1995).

                     Pesticide Formulations
                     Pesticide formulations may exist in any of the three following physical states:
                     liquid, dry, and pressurized gas.  The  liquid  formulation may  be applied
                     directly in liquid form or propelled as an aerosol.  Some common dry-based
                     formulations are dusts, wettable powders, granules, treated seed, bait pellets,
                     encapsulated, and cubes. Pressurized gas formulations are used primarily for
                     soil fumigation (USEPA, 1996). Gaseous pesticides can be subjected to high
                     pressures which often convert the formulation to a liquid which can be stored,
                     transported and applied from gas cylinders.

                     Repackaging of pesticide formulations is common when materials are to be
                     transferred from bulk storage to a smaller scale of packaging for use by a
                     consumer.  Products are typically  repackaged in smaller containers and
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                     consumer-specific labeling is added (USEPA, 1996).

                     In 1995, roughly 79 percent of all pesticides were used on agricultural
                     cropland. The remainder were used in private homes and gardens and on
                     commercial and industrial property (Aspelin, 1997). Therefore, although non-
                     agricultural pesticides are included in SIC code 2879 and thus the notebook,
                     the specific packaging or formulating requirements of those products are not
                     included.    However,   the  sales,  production,  pollutant  releases,  and
                     enforcement and compliance data reflect non-agricultural pesticides as well
                     as agricultural pesticides.

                     The majority of pesticides were used on only a few major crops: cotton, corn,
                     soybeans, and apples. The major pesticide chemicals used in United States
                     agricultural crop production are atrazine, metolachlor, metam sodium, methyl
                     bromide1, and dichloropropene (Aspelin, 1997).
    Figure 4: Product Distribution for SIC 2879, Pesticides and Miscellaneous
    Agricultural Chemicals    	 	^^^^
                                     1996 Production
                                     (in millions of pounds)
                                     568
                                               185
                        Herbicides
                        Fungicides
      Insecticides
      Plant Growth Regulators
      Source: American Crop Protection Association, asreportedin Chemical and Engineering News, June23,1998.
 1 Production and importation of methyl bromide is currently being phased out. It will be reduced from 1991 levels
 and will be completely phased out in 2005.
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                  Establishment Reporting Under FIFRA Section 7

                     Information reported under section 7 of the Federal Insecticide, Fungicide,
                     and Rodenticide Act (FIFRA) is another source of facility level data for the
                     pesticides industry. All establishments that produce pesticides in the United
                     States or that import pesticides into the United States are required to register
                     and report their production volume to the EPA.  These data differ from the
                     Census of Manufacturers data presented above for the agricultural chemical
                     industry as a whole.  The Census of Manufacturers data only covers facilities
                     that are manufacturing these products, while the FIFRA data system more
                     broadly includes establishments that "produce" these products. The term,
                     "produce" has been defined under FIFRA and 40 CFR Part 167 to mean "to
                     manufacture,  prepare, propagate,  compound, or  process any  pesticide,
                     including any pesticide produced pursuant to section 5 of FIFRA, any active
                     ingredient, or device, or to package, repackage, label, relabel, or otherwise
                     change the container of any pesticide or device." Repackaging or otherwise
                     changing the container of any pesticide or device in bulk amounts constitutes
                     pesticide production. Under FIFRA section 7, products are reported under
                     one of four product types:

                                  1) Technical material or active ingredient
                                  2) End-use blend, formulation, or concentrate
                                  3) Repackaged or relabeled product
                                  4) Device

                     The total number of establishments, domestic and foreign, that reported to
                     EPA under FIFRA section 7 are presented in Table 5. Although there are
                     approximately  twelve   to  thirteen  thousand   Active   Registered
                     Pesticide-Producing Establishments, table 5 below only lists establishments
                     that reported  actual  production  for the calender  year  1996.    The
                     establishments that reported either zero production or who were non-reporters
                     for calender year 1996 are not Included in the establishment number totals in
                     the  table.  The  significant  difference between  the  pesticide producing
                     establishment counts as reported under section 7 (8,612) and the pesticide and
                     agricultural chemical manufacturers n.e.c. reported by the Census (263) can
                     be attributed to the section 7 broad  inclusion of producers vs. the relatively
                     narrow, Census inclusion of manufacturers.  In addition, the Census of
                     Manufacturers uses SIC code definitions which lump many pesticide active
                     ingredient manufacturers into SIC codes that represent organic or inorganic
                     chemicals. Establishments classified under the first product type, as well as
                     some of the second, may include facilities classified under the chemical
                     manufacturing SIC codes 286 or 281. Also, the Census only counts a facility
                     in an SIC code if they report a product in that SIC code as their primary line
                     of business. Therefore, facilities producing a variety of products might not
                     be classified under all applicable SIC codes. For example, a facility which
                     produces many different types of fertilizers as well as some pesticides might
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Agricultural Chemical Industry
                     Introduction and Scope
                    only be counted under the fertilizer SIC codes by the Census Bureau to avoid
                    double counting of facilities.
Table 5: Establishment Counts Based on Product
Type*
Type
1
2
3
4
Product
Technical Material,
Active Ingredient
End-Use Blend,
Formulation,
Concentrate
Repackaged or
Relabeled Goods
Devices
Total
Total
555
2,590
5,267
200
8,612
Domestic
410
2,454
5,243
166
8,273
Foreign
145
136
24
34
339
Source: U.S.EPA, Enforcement, Planning, Targeting & Data
Division,, FIFRA, section 7 Data System, United States EPA. 1996.
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 Agricultural Chemical Industry
                       Introduction and Scope
    II.B.2. Industry Size and Geographic Distribution
                     Table 6 lists the facility size distribution within the nitrogenous fertilizer,
                     phosphatic fertilizer,  fertilizer  mixing,  and pesticide  and agrichemical
                     formulating industries.  For each industry code, the majority of facilities
                     employ less than 50 people.
Table 6: Facility Size Distribution for the Fertilizer, Pesticide, and Agricultural Chemical
Manufacturing Industry
Employees
per Facility
1-9 •> •
-1Q.-49" /
50-249
250-499
500-2499
Total
FERTILIZERS
Nitrogenous
Fertilizers
(SIC 2873)
Number
of
Facilities
60.
-47' *--,
43
1
1
152
Percentage
of
Facilities
39% •
31% - -%«
28%
1%
1%
100%
Phosphatic
Fertilizers (SIC
2874)
Number
of
Facilities
27~ ~
T^-.V *
15
6
5
75
Percentage
of
Facilities
"36%^
-"*'«*
29%
20%
8%
7%
100%
Fertilizers, Mixing
only
(SIC 2875)
Number
of
Facilities
205 v
'•166' "„
30
0
0
401
Percentage
of
Facilities
51% *-
41% '•
8%
0%
0%
100%
PESTICIDES
Pesticides and
other
Agrichemicals
(SIC 2879)*
Number
of
Facilities
108. .*
-95'', ''
45
7
8
263*
Percentage
of ''-
Facilities
,41%
36%.
17%
3%
3%
100%
Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, US Department of Commerce, Bureau of the Census
May 1995. , '
Note: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location, and employment
figures since 1992 are not reflected in these data.
United States EPA -has identified over 8, 600 registered pesticide producing establishments. The SIC code as it is defined by the
OMB only includes 263 of those establishments.
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Agricultural Chemical Industry
                      Introduction and Scope
                     Figure 5 shows the United States distribution of fertilizer manufacturing and
                     mixing facilities. The geographic distribution of nitrogenous and phosphatic
                     fertilizer manufacturers is determined by natural resources and demand.
                     Seventy percent of synthetic ammonia plants  in  the United States  are
                     concentrated in Louisiana, Texas, Oklahoma, Iowa, and Nebraska due to
                     abundant natural gas supplies. The majority of nitric acid plants are located
                     in agricultural regions such as the Midwest, South Central, and Gulf States
                     in order to accommodate the high volume of fertilizer usage. Florida has the
                     largest phosphate rock supply in the United States, thus phosphoric acid
                     manufacturing is concentrated primarily in Florida and spreads into  the
                     Southeast.
      FigureS: Geographic Distribution of the Fertilizer Industry (SIC 2873,2874,2875)
          Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, United States
          Department of Commerce, Bureau of the Census, May 1995.
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Agricultural Chemical Industry
                       Introduction and Scope
                     Table 7 further divides the geographic distribution of fertilizer manufacturing
                     and mixing facilities.  The top states in which the nitrogenous fertilizer,
                     phosphatic fertilizer, and fertilizer mixing industries are concentrated are
                     given along with their respective number of establishments. Florida's supply
                     of phosphate rock causes a concentration of phosphatic and mixed fertilizer
                     facilities, while nitrogenous fertilizer plants are often located near sources of
                     raw materials.
Table 7: States with the Largest Number of Fertilizer Manufacturing Facilities
States in which
industry is
concentrated, based
on number of
establishments
% of total
Nitrogenous
Fertilizers
(SIC 2873)
Top
States
California
Texas
Louisiana
Establish-
ments
17
12
8
24%
Phosphatic
Fertilizers
(SIC 2874)
Top
States
Florida
North
Carolina
Establish-
ments
15
9
32%
Fertilizers,
Mixing only
(SIC 2875)
Top
States
Florida
Ohio
Texas
Establish-
ments
42
31
26
25%
Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, US Department of Commerce,
Bureau of the Census, May 1995.
Note: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location,
and employment figures since 1992 are not reflected in these data.
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Agricultural Chemical Industry
                       Introduction and Scope
                     Figure 6 shows the United States distribution of pesticide formulating and
                     miscellaneous agrichemical formulating facilities. The distribution follows
                     the general distribution of the petrochemical industry (coasts  and Great
                     Lakes) which the industry relies on for its raw materials, and the distribution
                     of agricultural production in the United States  (Midwest and Great Plains
                     states).
      Figure 6: Geographic Distribution of the Pesticide Formulating and Miscellaneous
      Agrichemical Formulating Facilities  (SIC 2879)*	•     	
       Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, United States Department
       of Commerce, Bureau of the Census, May 1995.
       *  United States EPA has identified over 8,000 establishments that could fall within this SIC code as it is
       defined by the OMB.
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Agricultural Chemical Industry
                      Introduction and Scope
Table 8: Top United States Agricultural Chemical Companies
Rank
1
2
3
4
5
6
7
8
9
10
Company
IMC Global - Northbrook, IL
Zeneca Inc. - Wilmington, DE
Agrium United States Inc. - Spokane,
WA
CF Industries, Inc. - Lake Zurich, IL
PCS Nitrogen Inc. - Memphis, TN
Dowelanco (now named Dow
AgriSciences) - Indianapolis, IN
The Scotts Company - Marysville, OH
Cargill Fertilizer - Riverview, FL
ChemFirst Inc. - Jackson, MS
La Roche Industries Inc. - Atlanta, GA
1997 Sales
(millions of
dollars)
2,981
2,822
1,814
1,383
1,310
1,288
752
600
595
449
SIC Code(s) Reported
2874, 2875, 2819, 1474, 1475
2879, 2834,2899
2873
2873, 2874
2873, 2874
2879
2873, 2874, 2879, 0139, 2499,
3524
2874
2873,2865,3567,3312
2873, 5191, 2812, 2869, 3291,
3569
Source: Dun & Bradstreet's Million Dollar Directory, 1997
Note: Not all sales can be attributed to the companies agricultural chemical operations.
                    Dun & Bradstreet's Million Dollar Directory, compiles financial data on
                    United States  companies including those operating within the Fertilizer,
                    Pesticide, and Agricultural Chemical Industry.  Dun & Bradstreet ranks
                    United States companies, whether they are a parent company, subsidiary or
                    division, by sales volume within their assigned 4-digit SIC code.  Readers
                    should note that:  (1) companies are  assigned  a 4-digit SIC code that
                    resembles their principal industry most closely; and (2) sales figures include
                    total company sales, including subsidiaries and operations (possibly not
                    related to agricultural chemicals). Additional sources of company specific
                    financial information  include  Standard & Poor's Stock Report  Service,
                    Ward's Business Directory of United States Public and Private Companies,
                    Moody's Manuals, and annual reports.

                    The Bureau of the Census publishes concentration ratios, which measure the
                    degree of competition hi a market. They compute the value of shipments
                    percentage controlled  by the top 4, 8, 20, and 50 companies in a given
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Agricultural Chemical Industry
                      Introduction and Scope
                    industry. Within the agricultural chemical industry, the phosphatic fertilizer
                    industry had the highest concentration ratio for the top four companies in
                    1992,62 percent. The pesticide and other agricultural chemicals, nitrogenous
                    fertilizers, and fertilizer mixing industries' concentration ratios were 53,48,
                    and 19 percent respectively.

       II.B.3. Economic Trends

                    The United States is a major producer and exporter of agricultural chemicals.
                    It  is the largest producer of phosphatic fertilizers and pesticides and the
                    second  largest producer of nitrogenous fertilizers in the world (USDOC,
                    1998).

             Domestic Market Trends

                    The majority of important crops, such as corn and soybeans, are grown using
                    fertilizers and pesticides.  As a result, year-to-year changes in the domestic
                    demand for agrichemicals reflect the level of planted acreage, which in turn
                    is  affected by grain prices and weather  conditions.  Increases in planted
                    acreage of corn, feedgrains and other crops in recent years have resulted in
                    increased demand  and production of agrichemicals in the United States.
                    Industry shipments of agricultural chemicals should show modest annual
                    growth through the end of the decade (USDOC, 1998).

                    The Federal Agricultural Improvement and Reform Act of 1996 could have
                    a major long-term impact on the agricultural chemical industry.  This  law
                    gives farmers greater flexibility in making planting decisions and allows them
                    to rely  more on the marketplace as a guide for crop plantings. The  bill
                    eliminates the annual acreage set-aside program, thus potentially boosting the
                    levels of crop acreage (USDOC, 1998).

                    Agricultural chemical production showed little change between 1995  and
                    1996.  Total production was approximately 103 million pounds each year.
                    However, experts claim that due to lower dosage requirements for pesticides,
                    agrichemical demand is actually higher than it would appear. Pesticides  saw
                    a six percent rise in production from 1995  to 1996.  Nitrogenous fertilizer
                    production was up approximately seven percent, and phosphate production
                    increased slightly  except for its major product, diammonium phosphate.
                    Prices for agricultural chemicals rose three percent from 1995 to  1996, while
                    the number of production workers fell two percent (USDOC, 1998).

             International Market Trends

                    The United States accounts for more than 50 percent of world trade in
                    phosphatic fertilizers, with a two-thirds  share of total  trade in DAP
                    (diammonium  phosphate), the principal  phosphatic fertilizer product.
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Agricultural Chemical Industry	________	Introduction and Scope

                     Exports generally account for about half of total shipments for the United
                     States phosphatic fertilizer industry, with about half of all exports going to
                     China.

                     International markets, especially less developed nations in Asia and Latin
                     America, hold greater market potential for the agrichemicals industry as
                     population levels grow, income levels rise, and demands for better standards
                     of living and diets increase the need for grain production.  From the current
                     level of about 5.8 billion, the world population is expected to increase by
                     about 80 million each year between 1996 and 2000. Developing nations are
                     becoming more sophisticated in agricultural practices, thus increasing their
                     usage of fertilizers and pesticides to improve production (USDOC, 1998).

                     The United States has been a net exporter of pesticide chemicals, and this is
                     expected to continue through the turn of the century.  Exports of pesticides
                     accounted for about 25 percent of United States pesticide production in 1994,
                     according to The American Crop Protection Association.  United States
                     pesticide producers benefit  from a highly developed chemical sector and
                     strong demand from developing regions of the world. Nevertheless, export
                     opportunities are being restrained by industry-wide globalization as producers
                     are  choosing  to site facilities closer to end-use markets.   In addition,
                     regulatory reforms in Western  Europe, such  as the competitive access
                     provider plan, are expected  to limit prospects in that region,  currently the
                     largest destination for United States produced pesticides (USDOC, 1998).

                     International competition for the United States phosphatic fertilizer industry
                     generally comes from countries with phosphate rock reserves and capacity to
                     convert rock into phosphate chemicals. Diammonium phosphate imports are
                     expected to account for most of the growth in world trade, thus giving the
                     United States a promising outlook for this product.  Morocco possesses at
                     least 50 percent of the world's rock reserves and is the largest phosphate rock
                     exporter.  China and Russia are also major phosphate rock and fertilizer
                     producers, with Russia also a leading exporter of phosphate chemicals. In the
                     world pesticide markets, maj or competitors are companies based in Germany,
                     France, and Switzerland.

                     The United States is a net importer of nitrogenous fertilizers. Trinidad and
                     Tobago and Canada are the leading United States suppliers of nitrogen due
                     to their low-cost supplies of natural gas.

                     Agricultural biotechnology is beginning to play a major role in agricultural
                     pest control, spurred on by government pesticide restrictions, increased insect
                     resistance to  pesticides, and farmers'  demand for productivity  gains.
                     Genetically engineered plants will be higher yielding, more resistant to
                     disease and insects, and tolerant to herbicides. A number of companies have
                     received approvals for the use of genetically engineered seeds, including corn

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Agricultural Chemical Industry
             Chemical Releases and Transfers
                    and cotton, that are resistant to insects and herbicide tolerant. Commercial
                    usage should increase rapidly over the next few years (USDOC, 1998).
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Agricultural Chemical Industry
                 Industrial Process Description
III.  INDUSTRIAL PROCESS DESCRIPTION
                      This section describes the major industrial processes within the Fertilizer,
                      Pesticide, and Agricultural Chemical Industry, including the materials and
                      equipment used, and the processes employed. The section is  designed for
                      those interested in gaining a general understanding of the industry, and for
                      those interested in the inter-relationship between the industrial process and
                      the  topics described in subsequent sections of this profile ~  pollutant
                      outputs, pollution prevention opportunities, and federal regulations.  This
                      section does not attempt to replicate published engineering information that
                      is available for this industry.  Refer to Section IX for a list of resource
                      materials and contacts that are available.

                      This section specifically contains a description  of commonly  used
                      production processes, associated raw materials, the by-products produced or
                      released, and the  materials either recycled or transferred off-site.  This
                      discussion,  coupled with schematic drawings of the identified processes,
                      provide a concise description  of where wastes may be produced in the
                      process. This section  also describes the potential fate (via air, water, and
                      soil pathways) of these waste products.

                     The  three  most important  nutrients for  plant  growth are  nitrogen,
                     phosphorous, and potassium.  However,  the production  of the major
                     potassium fertilizer salts, or potash as they are commonly known, is typically
                     considered  an inorganic chemical  process (SIC  2819). Therefore, the
                     discussion of fertilizer production in this notebook is restricted to nitrogenous
                     and phosphatic mixtures. The fertilizer, pesticide, and agricultural chemical
                     industry can be divided into Nitrogenous Fertilizers, Phosphatic Fertilizers,
                     Fertilizers (Mixing-only), and the formulating and preparing of pesticides and
                     other agricultural chemicals.   A detailed description of the production
                     processes for nitrogenous and phosphatic fertilizers is presented here, along
                     with brief descriptions of the fertilizer mixing and pesticide formulating and
                     preparing industry.
III.A. Nitrogenous Fertilizers
                     The major nitrogenous fertilizers include synthetic ammonia, ammonium
                     nitrate, and urea. The various industrial processes used to manufacture these
                     products are described, as well as the production process for nitric acid, an
                     important intermediate hi nitrogenous fertilizer production.
       III.A.1. Synthetic Ammonia
                     Synthetic ammonia (NH3) is produced by reacting hydrogen with nitrogen at
                     a molar ratio of three to one. Nitrogen is obtained from the air, which is
                     primarily comprised of nitrogen (78 percent) and oxygen (21 percent) (Lewis,
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Agricultural Chemical Industry
               Industrial Process Description
                     1993).  Hydrogen is obtained from either the catalytic steam reforming of
                     natural gas (methane) or naptha, or as the byproduct from the electrolysis of
                     brine at chlorine plants. In the United States, about 98  percent of the
                     hydrogen used to  synthesize ammonia  is produced by catalytic steam
                     reforming of natural gas, and only 2 percent is obtained from chlorine plants
                     (USEPA, 1993a).

                     Six process steps are required to produce synthetic ammonia using the
                     catalytic steam reforming method:

                            1) natural gas desulfurization
                           2) catalytic steam reforming
                           3) carbon monoxide shift
                           4) carbon dioxide removal
                           5) methanation
                           6) ammonia synthesis.

                     The first, third, fourth, and fifth steps remove impurities such as sulfur, CO,
                     CO2 and water from the feedstock, hydrogen and synthesis gas streams. In the
                     second step, hydrogen is manufactured and mixed with air (nitrogen).  The
                     sixth  step produces anhydrous  ammonia from  the synthetic  gas.  An
                     anhydrous compound is inorganic and does not contain water either adsorbed
                     on its surface or combined as water of crystallization.  While almost all
                     ammonia plants  use these basic process steps, details such as operating
                     pressures, temperatures, and quantities of feedstock vary from, plant to plant.
                     Figure 7 shows a simplified process flow diagram of a typical ammonia plant
                     (USEPA, -1993a).

                     Natural gas desulfurization
                     In the natural gas desulfurization step, the sulfur content (primarily as H2S)
                     in natural gas feedstock is reduced to below 280 micrograms per cubic meter
                     to prevent poisoning of the catalyst used in the catalytic steam reforming step.
                     Desulfurization can be accomplished by passing the natural gas through a bed
                     of either activated carbon or zinc oxide. In both systems, the hydrogen sulfide
                     in the gas adsorbs to the surface of the activated carbon or zinc oxide medium
                     and the desulfurized natural gas passes through.

                     Over 95 percent of the  ammonia plants in the United States use activated
                     carbon fortified with metallic oxide additives for feedstock desulfurization.
                     After a certain  amount of impurities adsorb to the  activated carbon, its
                     effectiveness is reduced and it must be regenerated by passing superheated
                     steam through the carbon bed. The superheated steam strips out the sulfur
                     impurities, is condensed, and sent to the wastewater treatment plant. One
                     disadvantage of the activated carbon system is that some of the heavy
                     hydrocarbons in the natural gas  adsorb  to  the carbon,  decreasing its
                     effectiveness and lowering the heating value of the desulfurized gas.
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Agricultural Chemical Industry
                    Industrial Process Description
                      The remaining five percent of plants use zinc oxide for desulfurization. The
                      zinc oxide system is capable of absorbing up to 20 percent sulfur by weight


        Figure?: Typical Process of Ammonia Synthesis
              NATURAL GAS
   FEEDSTOCK
DESULFURIZATION
                                 FUEL
                    STEAM
                                           PRIMARY REFORMER
                        AIR
  SECONDARY
   REFORMER
              VOC
              EMISSIONS
                           PROCESS
                          CONDENSATE^_
                STEAM WASTEWATER
                      TO TREATMENT
                 PURGE GAS VENTED TO
                 PRIMARY REFORMER
                    FOR FUEL
HIGH TEMPERATURE
     SHIFT
LOW TEMPERATURE
     SHIFT
                                                 C02  '
                                              ABSORBER
  METHANATION
                       FINISHED NH,-*-
                                          AMMONIA SYNTHESIS
                                                              T
                                                                        EMISSIONS
                                                                       DURING CARBON
                                                                       REGENERATION
                                                                      FUEL COMBUSTION
                                                                         EMISSIONS
                               C02
                               EMISSIONS
                             C02  SOLUTION
                             REGENERATION
                           STEAM   WASTEWATER
                                   TO TREATMENT
                            CATALYTIC
                            AMMONIA SYNTHESIS
                LET-DOWN
                SEPARATOR
       Source: United States EPA, 1993a.
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Agricultural Chemical Industry
                 Industrial Process Description
                    (Hodge, 1 994). Zinc oxide is replaced rather than regenerated, which lowers
                    energy consumption and minimizes impact to the atmosphere.  The higher
                    molecular weight hydrocarbons are not removed; therefore, the heating value
                    of the natural  gas is not reduced.   However, it is  impractical and
                    uneconomical to replace the zinc oxide beds so few plants use it (USEPA,
                    1993a).

                    Catalytic steam reforming
                    Next, the desulfurized natural gas is preheated by mixing with superheated
                    steam. The mixture of steam and gas enters the primary reformer tubes
                    which are filled with a nickel-based reforming catalyst, and the tubes are
                    heated by natural gas or oil-fired burners. Approximately  70 percent of the
                    methane (CH4) is converted to hydrogen (H2) and carbon dioxide (CO 2),
                    according to the following reaction:

                               0.88CH4 + 1.26air + 1.24 H2O - 0.88 CO2 +N2 + 3H2

                    The remainder of the CH4 is converted to H2 and CO. This process gas is then
                    sent to the secondary reformer, where it is mixed with compressed hot air at
                    540°C (1004°F).  Sufficient air is added to produce a final synthesis gas
                    having a hydrogen-to-nitrogen mole ratio of three to one. The gas leaving the
                    secondary reformer (primarily hydrogen, nitrogen, CO, CO2, and H20) is then
                    cooled to 360°C (680°F) in a waste heat  boiler before being sent to the
                    carbon monoxide shift (USEPA,  1993a).

                    Carbon monoxide shift
                    After cooling, the secondary reformer effluent gas enters a high temperature
                    (350-400°C) CO shift converter which converts the CO to CO2, followed by
                    a low temperature (200-250°C) shift converter which continues to convert
                    CO to CO2 (Kroschwitz and Howe-Grant, 1992). The high temperature CO
                    shift converter is filled with chromium oxide initiator and iron oxide catalyst.
                    The following reaction takes place (USEPA, 1993a):
CO + H2O  -  CO2
                                                               H
                    The exit gas is then cooled in a heat exchanger before being sent to a low
                    temperature shift converter for ammonia, amines, and methanol where CO
                    continues to be converted to CO2 by a copper oxide/zinc oxide catalyst (Kent,
                    1992). In some plants, the gas is first passed through a bed of zinc oxide to
                    remove any  residual sulfur  contaminants  that would poison the low
                    temperature shift catalyst. In other plants, excess low temperature shift
                    catalyst is added to ensure that the unit will operate as expected. Final shift
                    gas from this converter is cooled from 210 to 110°C (410 to 230°F) and
                    unreacted steam is condensed and separated from the gas in a knockout drum.
                    The final shift gas then enters the bottom t>f the carbon dioxide absorption
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Agricultural Chemical Industry	   Industrial Process Description

                    system. The condensed steam (process  condensate) contains ammonium
                    carbonate ([(NH4)2 CO3 • H2O]) from the high temperature shift converter,
                    methanol (CH3OH) from the low temperature shift converter, and small
                    amounts of sodium, iron, copper, zinc,  aluminum and calcium.  Process
                    condensate is sent to the stripper to remove volatile gases such as ammonia,
                    methanol,  and carbon dioxide. Trace metals remaining in the process
                    condensate are typically removed in an ion exchange unit (USEPA, 1993a).

                    Carbon dioxide removal
                    In this step, CO2 in the final shift gas is removed. CO2 removal can be done
                    by using one of two methods: monoethanolamine (C2H4NH2OH) scrubbing
                    or hot potassium scrubbing. Approximately 8 0 percent of the ammonia plants
                    use monoethanolamine (MEA) for removing CO2. In this process, the CO2
                    gas is passed upward through an adsorption tower countercurrent to a 15
                    percent to 30  percent  solution of MEA  in water fortified with corrosion
                    inhibitors. After absorbing the CO2, the amine-CO2 solution is preheated and
                    regenerated in a reactivating tower. The reacting tower removes CO2 by
                    steam stripping and then by heating. The CO2 gas (98.5 percent CO2) is either
                    vented to the atmosphere or used for chemical feedstock in other parts of the
                    plant complex. The regenerated MEA is pumped back to the absorber tower
                    after being cooled in a heat exchanger and solution cooler (USEPA, 1993a).
                             i
                    Methanation
                    Carbon dioxide absorption is not 100 percent effective in removing CO2 from
                    the gas stream, and CO2 can poison the synthesis converter.  Therefore,
                    residual CO2 in the synthesis gas must be removed by catalytic methanation.
                    In a reactor containing a nickel catalyst and at temperatures of 400 to 600 ° C
                    (752  to 1112°F) and pressures up to 3,000 kPa (435 psia) methanation
                    follows the following reaction steps:

                                          CO2 + H2 - CO + H2 O
                                          CO + 3H2 - CH4 + H2O

                                        CH4 + 2H20  -CO2 + 4H2

                    Exit gas from the methanator is almost a pure three to one mole ratio of
                    hydrogen to nitrogen (USEPA, 1993a).

                    Ammonia Synthesis
                    In the synthesis step,  the hydrogen and nitrogen synthesis  gas from the
                    methanator is converted to ammonia.

                                            N2 +3H2 -> 2NH3

                    First, the gas is compressed to pressures ranging from 13,800 to 34,500 kPa
                    (2000 to 5000 psia), mixed with recycled synthesis gas, and cooled to 0°C

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Agricultural Chemical Industry
                Industrial Process Description
                    (32°F).  This results in a portion of the gas being converted to ammonia
                    which is condensed and separated from the unconverted synthesis gas in a
                    liquid-vapor separator and sent to a let-down separator. The unconverted
                    synthesis gas  is further compressed and heated to 180°C (356°F) before
                    entering a synthesis converter containing an iron oxide catalyst. Ammonia
                    gas exiting the synthesis converter is condensed and separated, then sent to
                    the let-down separator. A small portion of the overhead gas is purged to
                    prevent the buildup of inert gases such as argon in the circulating gas system.
                    Ammonia in the let-down separator is flashed to atmospheric pressure (100
                    kPa(14.5 psia)) at -33 °C (-27 °F) to remove impurities from the make-up gas.
                    The flash vapor is condensed in a let-down chiller where anhydrous ammonia
                    is drawn off and stored at low temperature (USEPA, 1993a).

                    Storage and Transport
                    Ammonia is typically stored at ambient pressure and -33 °C (-28 °F) in large
                    20,000 ton tanks. Some tanks are built with a double wall to minimize
                    leakage and insulate. If heat leaks into the tank and ammonia is vaporized, the
                    vapors are typically captured, condensed, and returned to the tank. Ammonia
                    is mostly transported by barge to key agricultural areas, but there is also a
                    small system of interstate ammonia pipelines (Kent, 1992).

       HI.A.2. Nitric Acid

                    Nitric acid (FfNO3) is produced by two methods. The first method utilizes
                    oxidation, condensation, and absorption of ammonia to produce a "weak"
                    nitric acid. Weak nitric acid  has a concentration ranging from 30 to 70
                    percent nitric  acid.  The second method combines dehydrating, bleaching,
                    condensing, and absorption to produce "high strength" nitric acid from weak
                    nitric acid. High strength nitric acid generally contains more than 90 percent
                    nitric acid (USEPA, 1993a).  The following text discusses  each of these
                    processes.

                    Weak Nitric Acid Production

                    Nearly all the weak nitric acid produced in the United States is manufactured
                    by the  high  temperature catalytic oxidation of  ammonia  as shown
                    schematically in Figure 8. This pro'cess typically consists of three steps:

                            1) ammonia oxidation
                           2) nitric oxide oxidation
                           3) absorption.

                    Each step corresponds to a distinct chemical reaction.

                    Ammonia Oxidation
                    During ammonia oxidation, a one to nine ammonia to air mixture is oxidized
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                     at a temperature of 750 to 800°C (1380 to 1470°F) as it passes through a
                     catalytic converter, according to the following reaction:
                                       4NH3 + 5O2   -  4NO + 6H£>

                     The most commonly used catalyst  is made of gauze squares of fine wire
                     constructed of 90 percent platinum  and 10 percent rhodium.  Under these
                     conditions the oxidation of ammonia to nitric oxide (NO) proceeds in an
                     exothermic reaction with 93 to 98 percent yield. Higher catalyst temperatures
                     increase reaction selectivity toward nitric oxide (NO) production.  Lower
                     catalyst temperatures tend to be more selective toward nitrogen (N2) and
                     nitrous oxide (N2O) (USEPA, 1993a). The nitric oxide then passes through
                     a waste heat boiler and a platinum filter in order to recover the precious metal
                     platinum (Kent, 1992).

                     Nitric Oxide Oxidation
                     The nitric oxide formed during the ammonia oxidation is further oxidized in
                     another process step. The nitric oxide process stream is passed through  a
                     cooler/condenser and cooled to 38°C (100°F) or less at pressures up to 800
                     kPa (116 psia). The nitric oxide reacts noncatalytically with residual oxygen
                     to form nitrogen dioxide and its liquid dimer, dinitrogen tetroxide:
                                     2NO  + O,
           2NO,   ->.
                    (A dimer is a small polymer whose molecule is composed of two molecules
                    of the same composition (Lewis, 1993).) This slow, homogeneous reaction
                    is temperature and pressure dependent.  Operating at low temperatures and
                    high pressures promotes maximum production of NO2 within a minimum
                    reaction time (USEPA, 1993a).

                    Nitrogen dioxide absorption
                    The final step introduces the gaseous nitrogen dioxide/dimer mixture into an
                    absorption process after being  cooled.   The mixture is pumped into  the
                    bottom of an absorption tower with trays, while liquid dinitrogen tetroxide
                    (N2O4) is added at a higher point.  Deionized water  enters the top of the
                    column. Both liquids flow countercurrent to the dioxide/dimer gas mixture.
                    The exothermic reaction occurs  as follows (USEPA, 1993a):
                                      3NO2 +
    H20
2HNO,  + NO
                    A secondary air stream is introduced into the column to re-oxidize the NO
                    that is formed.  This secondary air also removes NO2 from the product acid.
                    Oxidation of NO to NO2 takes place in the free space between the trays, while
                    absorption of NO2 into the water occurs on the trays. An aqueous solution of
                    55 to 65 percent (typically) nitric acid is withdrawn from the bottom of the
                    tower.  The acid concentration can vary from  30 to 70 percent nitric acid
                    depending upon the temperature, pressure, number of absorption stages, and
                    concentration of nitrogen oxides entering the absorber (USEPA, 1993a).
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                    There are two variations of the process described above to produce weak
                    nitric acid: single-stage pressure process and dual-stage pressure process. In
                    the past, nitric acid plants have been operated at a single pressure, ranging
                    from atmospheric pressure to 1400 kPa (14.7 to 203 psia). However, since
                    the oxidation of ammonia is favored by low pressures and the oxidation of
                    nitric oxide and the absorption of nitrogen dioxide are favored by higher
                    pressures,  newer plants tend to operate a dual-stage pressure system,
                    incorporating a compressor between the ammonia oxidizer and the condenser.
                    The oxidation reaction is carried out at pressures from slightly negative to
                    about 400 kPa (58 psia), and the absorption reactions are carried out at 800
                    to 1,400 kPa (116 to 203 psia) (USEPA, 1993a).

                    In the dual-stage pressure system, the nitric acid formed in the absorber
                    (bottoms) is usually sent to an external bleacher where air is used to remove
                    (bleach) any dissolved oxides of nitrogen (NO, NO2, etc.).  The bleacher
                    gases are then compressed and again passed through the absorber.  The
                    absorber tail gas (distillate) is sent to an entrainment separator for acid mist
                    removal.  Next, the tail gas is reheated in the  ammonia oxidation heat
                    exchanger to approximately 200°C (392°F). The gas is then passed through
                    catalytic reduction units for NOX emissions control. The final step expands
                    the gas in the power-recovery turbine.  The thermal energy produced in this
                    turbine can be used to drive the compressor.
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         Figure 8; Typical Process of Dual-Stage, Weak Nitric Acid Production
           TO ATMOSPHERE
            A.
                                                                         ENTRAINED
                                                                           MIST
                                                                         SEPERATOR
                                               LIQUID
                                               DINITROGEN
                                               TETROXIDE
                               COMPRESSOR
                                        WASTE COOLING
                                           WATER
                                                            HN03
                                                                            30-70%
                                                                            HNO3
                                                                            AIR
          Source: United States EPA, 1993a.
       High Strength Nitric Acid
                     High strength nitric acid (98 to 99 percent concentration) can be obtained by
                     concentrating  weak  nitric acid (30 to 70  percent  concentration) using
                     extractive distillation. Extractive distillation is distillation carried out in the
                     presence of a dehydrating agent. Concentrated sulfuric acid (typically 60
                     percent sulfuric acid) is most commonly used for this purpose. The weak
                     nitric acid cannot be concentrated by simple fractional distillation, in which
                     acid is concentrated  by removing water vapor in a column with trays or
                     plates.
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                    The nitric acid concentration process consists of feeding strong sulfuric acid
                    and 55 to 65 percent nitric acid into the top of a packed dehydrating column
                    at approximately atmospheric pressure. The acid mixture flows downward
                    and concentrated nitric acid leaves the top of the column as 99 percent vapor,
                    containing a small amount of NO2 and O2 resulting from dissociation of nitric
                    acid. The concentrated acid  vapor then  goes to a bleacher and a
                    countercurrent condenser system to condense strong nitric acid and  the
                    separate out the oxygen and nitrogen oxide by-products. The bleacher uses
                    air to strip nitrogen oxides out of the nitric  acid and the countercurrent
                    condenser system cools the vapor by flowing air through the vapor causing
                    droplets to separate out.

                    These nitrogen oxide by-products .then flow to an absorption column where
                    the nitric oxide mixes with auxiliary air to form NO2, which is recovered as
                    weak nitric acid. Inert and unreacted gases are vented to the atmosphere from
                    the top of the absorption column. Emissions from this process are relatively
                    small compared to weak acid production (USEPA, 1993a).  Figure 9
                    illustrates a typical high strength nitric acid production process.
              Figure 9: Typical Process Diagram of High Strength Nitric Acid Production
                       55-65%
                       HN03
                                      99% HNO3, NO2, O2
                                                               AIR, NOXTO
                                                               ATMOSPHERE
                60%
                H2SO4
                                                     BLEACHER
                                                     CONDENSER
                                                                    WEAK HN03
               Source: Adapted from United States EPA, 1993a.
       III.A.3. Ammonium Nitrate and Urea

                     The manufacture steps for ammonium nitrate (NH4NO2) and urea (CO(NH2)2)
                     are similar.   In both cases, several major unit operations are involved,
                     including:

                            1)  solution formation
                            2)  concentration   ,
                            3)  solids formation
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                           4)  finishing
                           5)  screening
                           6)  coating
                           7)  product bagging and/or bulk shipping.

                    These operations are shown schematically in Figure 10. Not all steps are
                    always necessary depending on the end product desired. For example, plants
                    producing ammonium nitrate or urea liquid solutions alone use only the
                    solution formation, solution blending and bulk shipping operations. Plants
                    producing a solid product may employ all of the operations.

                    Solution synthesis
                    Ammonium nitrate.
                    Ammonium nitrate plants produce an aqueous ammonium nitrate solution
                    through the reaction of ammonia and nitric acid in a neutralizer where water
                    is evaporated by the heat of the reaction as follows:
NH3 + HNO3
        NH4NO3
                                                              26 kcal/g mol
                    The temperature, pressure, and final concentration of the ammonium nitrate
                    are interdependent.  Higher temperatures and pressures can be used to
                    produce  a higher  concentration of ammonium nitrate  (Hodge, 1994);
                    however, the temperature of the operation should be below 120°C (250°F)
                    in order to prevent explosions. Up to 99.5 percent of the ammonia and nitric
                    acid is typically converted to ammonium nitrate (Kent, 1992). Ammonium
                    nitrate solution can then be used as an ingredient for nitrogen solution
                    fertilizers or concentrated to a solid form.

                    Urea.
                    In the urea solution synthesis operation, ammonia (NH3) and carbon dioxide
                    (CO2) are reacted to form ammonium carbamate (NH 2CO 2NH 4) as follows:
                                          2NH  + CO
                  NH2C02NH4
                    Typical operating conditions include temperatures from 180 to 200°C (356
                    to 392°F), pressures from 14,000 to 25,000 kPa (140 to 250 psia),  molar
                    ratios of NH3 to CO2 from 3:1 to 4:1, and a retention time of twenty to thirty
                    minutes.  The ammonium carbamate is then dehydrated to yield 70 to 77
                    percent aqueous urea solution. This reaction follows: (USEPA, 1993a)

                                    NH2CO2NH4  -  NH2CONH2 + H2O

                    Urea solution can be used as an ingredient of nitrogen solution fertilizers, or
                    it can be concentrated further to produce solid urea.
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                     Solids Concentration
                    Ammonium nitrate.
                     To produce a solid product, the aqueous ammonium nitrate solution is
                     concentrated in an evaporator or concentrator. The resulting liquid "melt"
                     contains about 95 to 99.8 percent ammonium nitrate at approximately 149 °C
                     (300°F). This melt is then used to make solid ammonium nitrate products
                     (USEPA, 1993a).

                     Urea.
                     The three methods of concentrating  the  urea  solution  are  vacuum
                     concentration, crystallization, and atmospheric evaporation.  The method
                     chosen depends upon  the  level of biuret (NH2CONHCONH2) impurity
                     allowable hi the end product. Biuret can cause mottling in urea solutions,
                     reducing the fertilizers effectiveness in foliar applications (Kent, 1992).
                     Aqueous  urea solution decomposes with heat to  biuret  and ammonia.
                     Therefore, if only a low level of biuret impurity is allowed in the end product,
                     the method with  the  least heat requirement will be chosen,  such as
                    .crystallization and vacuum concentration (Kent,  1992). However, the
                     simplest and most common method of solution concentration is atmospheric
                     evaporation.

                     Solids Formation
                     Prilling and granulation are the most common processes used to produce
                     solid ammonium  nitrate  and urea. Prills are round  or needle-shaped
                     artificially prepared aggregates of a material. To produce prills, concentrated
                     melt is sprayed into the top of a prill tower. In the tower, melt droplets fall
                     countercurrent to a rising air stream that  cools and solidifies the falling
                     droplets into prills.  Prill density can be  varied  by  using  different
                     concentrations of ammonium nitrate melt. Low density prills, in the range of
                     1.29 specific gravity, are formed from a 95 to 97.5 percent ammonium nitrate
                     melt, and high density prills, in the range of 1.65 specific gravity, are formed
                     from a 99.5 to 99.8 percent melt. Low density ammonium nitrate prills are
                     used for making blasting agents because they are more porous than high
                     density prills and will absorb  oil.  Most high density  prills are used as
                     fertilizers (USEPA, 1993a).

                     Granulated ammonium nitrate  and urea are produced  by spraying a
                     concentrated melt (99.0 to 99.8 percent) onto  small seed  particles of
                     ammonium nitrate or urea in a long rotating cylindrical drum. As the seed
                     particles rotate in the drum, successive layers of the nitrogenous chemical are
                     added to the particles, forming granules. Pan granulators operate on the same
                     principle as drum granulators, except the solids are formed in a large, rotating
                     circular  pan.  Pan  granulators produce a solid product  with  physical
                     characteristics similar to those of drum granules (USEPA, 1993 a).
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                    Although not widely used, additives such as magnesium nitrate or magnesium
                    oxide may be injected directly into the melt stream. Additives can serve three
                    purposes: to raise the crystalline transition temperature of the final solid
                    product in order to retain its strength and density; to act as a desiccant,
                    drawing water  into the final  product  to  reduce caking; and  to  allow
                    solidification to occur at a low temperature by reducing the freezing point of
                    molten ammonium nitrate. (Kent, 1992)

                    Solids Cooling
                    The temperature of the nitrogenous product exiting the solids formation
                    process  is  approximately  66  to 124°C (150 to 255°F).  To prevent
                    deterioration and agglomeration, the product must be cooled before storage
                    and shipping. Typically, rotary drums or fluidized beds are used to cool
                    granules and prills leaving the solids formation process. Because low density
                    prills have a high moisture content, they require drying in rotary drums or
                    fluidized beds before cooling (USEPA, 1993a).

                    Solids Screening
                    Since the solids are produced in a wide variety  of sizes, they must be
                    screened for consistently sized prills or granules. After cooling, off size prills
                    are  dissolved and recycled back to the solution concentration process.
                    Granules are  screened  before  cooling. Undersize particles are returned
                    directly to the granulator and oversize granules may be either crushed and
                    returned to the granulator or sent to the solution concentration process
                    (USEPA, 1993a)..

                    Solids Coating
                    Following screening, products  can be coated in a rotary drum to prevent
                    agglomeration during storage and shipment. The  most common coating
                    materials are clays and diatomaceous earth. However, the use of additives in
                    the melt before solidification may preclude the use of coatings.

                    The solid product is stored and shipped in either bulk or bags. The majority
                    of solid product is bulk shipped in trucks, enclosed railroad cars, or barges,
                    and approximately ten percent of solid ammonium nitrate and urea produced
                    in the United States is bagged (USEPA,  1993a).
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Figure 10: Typical Process for Ammonium Nitrate and Urea Manufacturing
                                                                 PARTICULATES
                      WASTEWATER •*
 AMMONIA-
 CARBON _
 DIOXIDE
   Source: United States EPA, 1993a.
 III.B. Phosphatic Fertilizers
                     The primary products of the phosphatic fertilizers industry are phosphoric
                     acid,  ammonium  phosphate,   normal  superphosphate,  and  triple
                     superphosphate. Phosphoric acid is sold as is or is used as an intermediate in
                     producing other phosphatic fertilizers.   Monoammonium  phosphate is
                     favored for its high phosphorous content, while diammonium phosphate is
                     favored for its high nitrogen content. Normal superphosphate has a relatively
                     low concentration of phosphorous, however it is used in mixtures because of
                     its low  cost. Triple superphosphate provides  a high concentration of
                     phosphorous, more than 40%  phosphorous pentoxide.  The industrial
                     processes for each of these products are described below.
       III.B.l. Phosphoric Acid (Wet Process)
                     In a wet process phosphoric acid facility (shown schematically in Figure 11),
                     phosphoric acid is produced by reacting sulfuric acid (H2SO4) with naturally
                     occurring phosphate rock. The phosphate rock is mined, dried, crushed until
                     60 to 70 percent of the rock is  less than 150 pum. in diameter, and then
                     continuously fed into the reactor along with sulfuric acid (UNEP, 1996). The
                     reaction also combines calcium from the phosphate rock with sulfate,
                     forming calcium sulfate (CaSO4), commonly referred to as gypsum. Gypsum
                     is separated from the reaction solution by filtration.
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                    Facilities in the United States generally use a dihydrate process that produces
                    gypsum in the form of calcium sulfate with two molecules of water (CaSO4
                    • 2H 2O or calcium sulfate dihydrate). Japanese phosphoric acid facilities use
                    a hemihydrate process which produces calcium sulfate with a half molecule
                    of water (CaSO4 • Vz H 2O).  This one-step hemihydrate process has the
                    advantage of producing wet process phosphoric acid with a higher phosphate
                    pentoxide (P2O5) concentration and less impurities than the dihydrate process .
                    Due to these  advantages, some United States companies have recently
                    converted to the hemihydrate process. However, since most wet process
                    phosphoric acid is still produced by the dihydrate process, the hemihydrate
                    process will not be discussed in detail here.

                    A simplified reaction for the dihydrate process is as follows:

                                 + 3H2S04 +  6H20  -  2H3PO4 + 3[CaSO4 • 2H2O]I
                    To make the strongest phosphoric acid possible and to decrease evaporation
                    costs,  a highly concentrated 93 percent sulfuric acid is normally used.
                    Because the proper ratio of acid to rock in the reactor is critical, precise
                    automatic process control equipment is employed in the regulation of these
                    .two feed streams (USEPA, 1993a).

                    During the reaction, gypsum crystals are precipitated and separated from the
                    acid by filtration. The separated crystals must be washed thoroughly to yield
                    at least a 99 percent recovery of the filtered phosphoric acid. After washing,
                    the slurried gypsum is pumped into a gypsum settling pond for storage. Water
                    is siphoned off and recycled through a surge cooling pond to the phosphoric
                    acid process. Depending on a variety of factors, such as average ambient
                    temperature and annual rainfall, settling and cooling ponds may require
                    between 0.25 and 1.0 acre for each ton of daily P205 capacity (TFI, 1999).

                    Considerable heat is generated in the reactor when the sulfuric acid  and
                    phosphate rock react. In older plants,  this heat was removed by blowing air
                    over the hot slurry surface. Modern plants vacuum flash cool a portion of the
                    slurry, and then recycle it back into the reactor.

                    Wet process phosphoric acid normally contains  26  to 30 percent P2O5. In
                    most cases, the acid must be further  concentrated to meet phosphate feed
                    material specifications for fertilizer production. Depending on the types of
                    fertilizer to be produced, phosphoric acid is usually concentrated to 40 to 55
                    percent P2O5 by using two or three vacuum evaporators (USEPA, 1993a).
                    These evaporators operate with a forced circulation and generate a vacuum
                    through vacuum pumps, steam  ejectors,  or an   entraining condenser
                    downstream of the evaporator. Figure 12 illustrates  a vacuum evaporator.
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          Figure 11; Typical Process of a Wet Process Dihydrate Phosphoric Acid Plant


PHOSPHATE
ROCK
WEIGH
FEEDER

^. \ -^.
^"
SULFURIC
ACID ^
~~i
/\ VACUUM
FLASH
COOLER


\ / WATER
\/
y v A
REACTOR •*• GYPSUM ^. CRYSTAL
' """'"" ^ FILTRATION *"~ WASHES
1
PHOSPHORIC
ACID (26-30%)






A
	 ^. SETTLING
"^ POND
1
GYPSUM

        Source: Adapted from United States EPA, 1993 a.
                 Figure 12: Typical Vacuum Evaporator Process
                             TO ACID PLANT -«
                                                      TO VACUUM
                                                      AND HOT WELL
                                        HYDROFLUOSILJC ACID
                  Source: United States EPA, 1993a
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       III.B.2. Ammonium Phosphate
                    Diammonium phosphate (DAP)  and monoammonium phosphate are the
                    major types of ammonium phosphatic fertilizer. Ammonium phosphates are
                    produced by reacting phosphoric  acid with  ammonia.  The ammonium
                    phosphate  liquid slurry  produced  is then  converted to solid granules.
                    Approximately 95 percent of ammoniation-granulation plants in the United
                    States use a rotary drum mixer developed and patented by the Tennessee
                    Valley Authority (TVA).

                    In the TVA DAP process, phosphoric acid is mixed in an acid surge tank with
                    93 percent sulfuric acid (H2SO4) and recycled acid from wet scrubbers. The
                    mixed acids are then partially neutralized with liquid or gaseous anhydrous
                    ammonia in a brick-lined acid reactor. All of the phosphoric acid and
                    approximately 70 percent of the ammonia needed to complete the reaction are
                    introduced into this vessel. A slurry of ammonium phosphate and 22 percent
                    water are produced and sent through steam-traced lines to the ammoniator-
                    granulator.

                    Slurry from the reactor is distributed in the rotary drum granulator, and the
                    remaining ammonia (approximately 30 percent) is sparged under the slurry.
                    The basic rotary drum granulator consists of an open-ended, slightly inclined
                    rotary cylinder,  with retaining rings at each end and a  scraper or cutter
                    mounted inside the drum shell. A rolling bed of dry material is maintained
                    in the unit while the slurry  is introduced through distributor pipes set
                    lengthwise in the drum. Gravity forces the slurry to travel through the turning
                    granulator to the lower end. Moist DAP granules are then discharged into a
                    rotary dryer, where excess water is evaporated and the chemical reaction is
                    accelerated to completion by the dryer heat.  Dried granules are cooled and
                    then sized on vibrating screens. The product ranges in granule diameter from
                    one to four millimeters (mm).  The oversized granules are crushed, mixed
                    with the  undersized, and recycled back to the ammoniator-granulator.
                    Product-size DAP granules are  allowed  to cool,  screened, bagged, and
                    shipped. Before being exhausted to the atmosphere, particulate and ammonia
                    rich off-gases from the  granulator, cooler, and screening operations pass
                    through cyclones and wet scrubbers (USEPA, 1993a).

                    TVA developed two minor modifications  in their DAP process to  produce
                    Monoammonium Phosphate  (MAP).  In one,  the  phosphoric  acid is
                    ammoniated to  an ammonia  to phosphoric acid ratio of only 0.6 in the
                    preneutralizer and then  1.0 in the granulator.  This compares to a ratio of
                    about  1.4 for DAP.  With the  second modification, the ammonium to
                    phosphoric acid  ratio is brought to 1.4 in the preneutralizer, then additional
                    phosphoric acid  is added in the granulator to bring the ratio back to  1.0. The
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                    second method is preferred by industry because higher temperatures may be
                    used to dry the MAP,'increasing production rates (Kent, 1992).
                                                          (

                    A schematic diagram of the ammonium phosphate process flow diagram is
                    shown in Figure 13.
 Figure 13: Simplified Process Flow Diagram of Diammnonium Phosphate Production
   GYPSUM
   POND
   WATER

4


	 \

JL
<
  PHOSPHORIC.
  ACID
  SULFURIC
  ACID
    ANHYDROUS
    AMMONIA
                                                           /CYCLONE
                                                         OVERSIZE
                COOLING AIR
                                                                         MILL
AMMONIATOR
GRANULATi
                             DUST
                             SUPPRESSANT
                                                                          PRODUCT
                                           UNDERSIZE
                                                             DUST
                                                             SUPPRESSANT
   Source: U.S.EPA, 1993aandTFI, 1999
       III.B.3.  Normal Superphosphate
                    Normal superphosphates (NSP) are prepared by reacting ground phosphate
                    rock with 65 to 75 percent sulfuric acid to produce a solid fertilizer material.
                    NSP is most often used as a high-phosphate additive in the production of
                    granular fertilizers.   It can  also be granulated for sale  as granulated
                    superphosphate or granular mixed fertilizer.

                    There are two primary types of sulfuric acid used  in superphosphate
                    manufacture: virgin and spent acid. Virgin acid is produced from  elemental
                    sulfur, pyrites, and industrial gases and is relatively pure.  Spent acid is a
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                    recycled waste product from various industries that use large quantities of
                    sulfuric acid. Problems encountered with using spent acid include unusual
                    color, unfamiliar odor, and toxicity. An important factor in the production
                    of normal superphosphates is the amount of iron and aluminum in the
                    phosphate rock. Aluminum (as A12O3) and iron (as Fe2O3) above five percent
                    imparts an extreme stickiness to the superphosphate and makes it difficult to
                    handle (USEP A, 1993a).

                    A generalized process diagram  of normal superphosphate production is
                    shown in Figure 14.  Ground phosphate rock is weighed and mixed with
                    sulfuric acid (H2SO4) and held in an enclosed area for about 30 minutes until
                    the reaction is partially completed. The mixing may be done in a cone mixer,
                    which relies on an inputted swirling motion of the acid to mix the rock and
                    acid, a pug mill, which operates with one or two mixing shafts, or a pan
                    mixer, which agitates the solution.  The reaction is (AWMA, 1992):  •
CaIO(PO4)6F2CaCO3
   1 1H2SO4 - 6H3PO4
   2HF + CO2 + H2O
                                                                  !CaSO4*nH2O
                    The mixture is then transferred, using an enclosed conveyer known as the
                    den, through the cutter which breaks up clumps, and finally to a storage pile
                    for curing. Off-gases from the reactor are typically treated in a wet scrubber.
                    Particulates  throughout  the  process  are controlled with cyclones and
                    baghouses (USEP A, 1993a).

                    To produce granulated normal superphosphate, cured superphosphate is fed
                    through a clod breaker and sent to a rotary drum granulator where steam,
                    water, and acid may be added to aid in granulation.  Material is processed
                    through a rotary drum granulator, a rotary dryer, and a rotary cooler, and is
                    then screened to specification similar to the process used for ammonium
                    nitrate and urea.  Finally, it is stored in bagged or bulk form prior to being
                    sold (USEP A, 1993a).
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   Figure 14:  Typical Process for Normal Superphosphate Manufacturing
   Dust
        Participate
        emissions
                                     Particulate
                                     emissions
                                                             To gypsum
                                                               pond
                                                                Particulate and
                                                               fluoride emissions
                                                                             Particulate and
                                                                          *- fluoride emissions
                                                                             (uncontrolled)
                                                                                   Product
   Source: United States EPA, 1993a.
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       JIII.B.4.  Triple Superphosphate
                    Triple superphosphate provides a high concentration of phosphorous.  Two
                    processes have been used to produce triple superphosphate: run-of-the-pile
                    (ROP-TSP) and granular (GTSP).   GTSP yields larger, more  uniform
                    particles with improved storage and handling properties than ROP-TSP. At
                    this time, no facilities in the United States are producing ROP-TSP, so only
                    the GTSP process is described here.

                    Most GTSP material is made with the Dorr-Oliver slurry granulation process,
                    illustrated  in  Figure  15. This  process  is  similar to that for normal
                    superphosphates with the maj or exception being that phosphoric acid is used
                    instead of sulfuric acid. In this process, ground phosphate rock or limestone
                    is reacted with phosphoric acid in one or two reactors in  series (USEPA,
                    1993a). The reaction is:
Ca5F(P04)3+ 7H3P04
        5H2O
                                                          5Ca(H2PO4)2-H2O +HF
                    (Hodge, 1 994) The phosphoric acid used in this process has a relatively low
                    concentration (40 percent P2O5). The lower strength acid maintains the slurry
                    in a fluid state during a mixing period of one to two hours.  A small
                    sidestream of slurry is continuously removed and distributed onto dried,
                    recycled fines in a granulator, where it coats the granule surfaces and builds
                    up its size.

                    Granules are then dried in a rotary dryer, elevated and passed through screens
                    to eliminate oversize and undersize granules. Oversize granules are crushed
                    and sent back to the first screen, while undersize ones are sent  into the
                    emission control systems. The granules within the size range of the product
                    are then cooled and stored in a curing pile where the reaction is completed.
                    Particulates from the rock handling, drying, screening, cooling, and storing
                    processes are typically controlled with cyclones and bag houses and off-gases
                    from the reactor, granulator, and cyclones and baghouses are typically treated
                    with wet scrubbers (USEPA, 1993a).
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  Figure 15: Typical Process for Triple Superphosphate
       Source: United States EPA, 1993a
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III.C. Fertilizer Mixing
                     A significant part of the fertilizer industry only purchases fertilizer materials
                     in bulk from fertilizer manufacturing facilities and mixes them to sell as a
                     fertilizer formulation.   Fertilizer mixing facilities use  many different
                     materials in their blends. The most common granular fertilizer materials are
                     listed in Table 9.
Table 9: Fertilizer Materials Used in Bulk Blends

Ammonium nitrate
Urea
Ammonium sulfate
Diammonium phosphate (DAP)
Monoammonium phosphate (MAP)
Triple Superphosphate
Normal superphosphate
Potassium chloride
Typical Grade
N-P2O5-K20
31-0-0
46-0-0
21-0-0
18-46-0
11-52-0
0-46-0
0-20-0
0-0-60
Percent of
fertilizer plants
using this
material
41%
66%
22%
95%
11%
78%
4%
94%
Source: "Retail Marketing of Fertilizers in the United States, " by Hargett, Norman
and Ralph Pay, 1980.
                     DAP is  favored for fertilizer mixing because of its ease in storage and
                     handling, convenient low nitrogen  and high phosphorous content, and
                     compatibility with almost any other material. Granular triple superphosphate
                     is also very popular, but is incompatible with urea, a common nitrogen
                     source. Therefore, TSP is commonly used in no-nitrogen blends necessary
                     for legumes. Ammonium sulfate has the lowest nitrogen content of the major
                     nitrogen sources, however its  production cost is quite  low.  Potassium
                     chloride is  the only major potassium  source used in fertilizer blending.
                     Additional materials may also be added to the blends, such as micronutrients
                     and pesticides (Nielson, 1987).
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                     Inert ingredients may also be added to fertilizer mixtures to improve the
                     consistency or ease of application. Inert ingredients include sands, clays, and
                     water.

                     Fertilizer mixing plants consist of five primary phases:

                        1. mixing and storing
                        2. moving materials to mixers
                        3. proportioning of materials
                        4. mixing, and
                        5. moving the finished blend to holding bins or transport containers

                     Fertilizer materials may be mixed as bulk blends or formed into granulations
                     by a variety of processes.  Bulk blending is a dry process, where different
                     fertilizers are combined.  Materials are typically received by rail cars and
                     transferred through elevators to storage areas.  Front-end loaders then carry
                     the materials to weighing hoppers which feed into the mixers. There are two
                     types of mixers most commonly used: the horizontal axis rotary drum mixer
                     and the inclined axis rotary drum mixer. The inclined axis mixer is similar
                     to a cement mixer in design and appearance. Ribbon-type bulk-blend mixers
                     are also used in some plants. A ribbon-type mixer has an axial shaft with
                     mixing spokes radiating out of the shaft in a configuration which forces the
                     blend to flow in a ribbon-like pattern through the mixture (Nielson, 1987).

                     After preparation and initial bulk blending of materials, granulation may be
                     employed in order to form larger fertilizer particles with multi-nutrient
                     compositions. Granulation of mixed fertilizers may be  accomplished by
                     steam granulation, slurry granulation, melt, or compaction granulation.

                     Steam granulation is  primarily used in Europe and Australia. The process
                     results in little chemical reaction in order to maintain the P2O5 content of the
                     fertilizer. Plasticity and agglomeration of the fertilizer materials is promoted
                     by the injection of steam into rotating pans, rotary drums,  or pug mills. The
                     particles are then dried with heated air in a rotary drum dryer and cooled in
                     a rotary drum cooler. In some cases, particles may be coated with chalk or
                     clay to prevent caking (Hoffmeister, 1993).

                     Slurry granulation is more commonly used in the United States The process
                     involves  a chemical reaction of the feed ingredients. In slurry granulation,
                     one of the feed ingredients is prepared as a slurry and reacted with the others
                     in a preneutralizer.  The  slurry is then  fed to a granulator such as the
                     ammoniator-granulator developed by the  TVA.  Fertilizer producers in the
                     United States found that higher concentrations of acid could be fed to this
                     preneutralizer-granulator process than to a granulator alone, thus increasing
                     the grades of fertilizers and making the TVA process popular in the United
                     States (Hoffmeister, 1993).
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                     Another granulation process similar to slurry granulation is melt granulation.
                     The slurry feed is replaced by a hot, concentrated, almost anhydrous melt of
                     feed fertilizer, typically ammonium phosphate, prepared in a pipe reactor.
                     The hot melt provides the plasticity necessary for granulation.  The granules
                     cool first in the granulator and then in the cooler, eliminating the need for a
                     dryer.

                     Compaction granulation is based on the  fact that most materials are
                     semiplastic and when subj ected to high pressures, the materials will compact,
                     deform, and it is possible to roll them out into flat, stable sheets.  These
                     sheets are then cracked, forming granule-size chips which are most stable and
                     less prone to caking than other  granulations.  This process has been
                     successful for many fertilizer mixtures, particularly those including potassium
                     chloride and  ammonium phosphates and superphosphates.  Ammonium
                     sulfate, however, has limited crystal plasticity, making it unsuitable for
                     compaction granulation (Hoffmeister, 1993).

                     The mixtures are then typically bagged in woven polypropylene bags for
                     strength and resistance, with liner bags to prevent leaks. The bags are either
                     clamped, tied, heat sealed, or sewn, sewing being the cheapest and most
                     common method (Nielson, 1987).

III.D. Pesticide Formulating Processes

                     Pesticide formulation involves the  process of mixing, blending, or diluting
                     one or more pesticide active ingredients (AIs) and inert ingredients to obtain
                     a product  used  for additional processing or an end-use (retail) product.
                     Formulation does not involve an intended chemical reaction (i.e., chemical
                     synthesis).  AIs are produced at  separate facilities not included in this
                     notebook.   Pesticide formulations take many forms: water-based liquid;
                     organic solvent-based liquid; dry products in granular, powder, and solid
                     forms;  pressurized gases;  and aerosols.  The formulations  can be in a
                     concentrated form requiring dilution before application, or they can be ready
                     to apply. The packaging of the formulated pesticide product depends on the
                     type of formulation.  Liquids generally  are packaged into jugs, cans, or
                     drums; dry formulations generally are packaged into bags, boxes, drums, or
                     jugs; pressurized  gases  are  packaged into cylinders;  and  aerosols are
                     packaged into aerosol cans.

                     Formulating, packaging,  and repackaging is performed in a variety of ways,
                     ranging from very sophisticated and automated formulating and packaging
                     lines to completely manual lines.  Descriptions of liquid formulating and
                     packaging, dry formulating and packaging, aerosol packaging, pressurized
                     gas formulating and packaging, and repackaging operations  are provided
                     below.
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   III.D.l.  Liquid Formulating and Packaging
                     Liquid formulations contain mixtures of several raw materials, including AIs,
                     inert ingredients such as base solvents, emulsifiers, or surfactants.  The
                     solvent must be able to dissolve the AIs and other ingredients.  It may be
                     water or an organic chemical,  such as isopropyl  alcohol or petroleum
                     distillate. In some cases, the formulation is an emulsion and contains both
                     water and an organic solvent. Solid materials, such as powders or granules,
                     may also be used as part of a liquid formulation by dissolving or emulsifying
                     the dry materials to form a liquid or suspension. The formulated product may
                     be in a concentrated form requiring dilution before application, or may be
                     ready to apply.

                     Typical liquid formulating lines consist of storage tanks or containers to hold
                     active and inert raw materials and a mixing tank for formulating the pesticide
                     product. A storage tank may also be used on the formulating line to hold the
                     formulated pesticide  product, prior to a packaging step.  Facilities may
                     receive their raw materials  in bulk and store them in bulk storage tanks, or
                     they may receive the raw materials in smaller quantities, such as 55-gallon
                     drums, 50-pound bags, or 250-gallon  minibulk refillable containers  or
                     "totes." These raw materials are either piped to the formulation vessel from
                     bulk storage tanks or added directly to the vessel  from drums, bags, or
                     minibulks. Typically, water or the base solvent is added to  the formulation
                     vessel in bulk quantities (USEPA, 1996). A typical liquid formulating line
                     is shown in Figure 16.

                     The formulating line may also include piping and pumps for moving the raw
                     material from the storage tanks  to  the  mixing tank, and for moving
                     formulated pesticide product to the packaging line. Other items that may be
                     part of the line are premixing tanks, stirrers, heaters, bottle washers, and air
                     pollution control equipment. Some lines may also have refrigeration units for
                     formulation and storage equipment, scales, and other equipment.

                     Many liquid formulations  are packaged by simply transferring the final
                     product into containers.  Small  quantities of product are  often manually
                     packaged by gravity feeding the product directly from the formulation tank
                     into the product  container.  For  larger quantities,  the process is often
                     automated. Formulated product is transferred to the packaging line through
                     pipes or hoses, or is received from a separate formulating facility and placed
                     in a filler tank. A conveyor belt is used to carry product containers, such as
                     jugs, bottles, cans, or drums, through the filling unit, where nozzles dispense
                     the appropriate volume of product. The belt then carries the containers to a
                     capper, which may be automated or manual, and to a labeling unit. Finally,
                     the containers are packed into shipping cases (USEPA, 1996).
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     Figure 16: Typical Process for Liquid Formulating
              RAW MATERIAL
              DRUM/BULK TANK
               LIQUID PESTICIDE
               ACTIVE
               INGREDIENT (PAI)
               RAW MATERIAL
               DRUM/BULK TANK
               INERT
               INGREDIENTS
               /SOLVENTS
               /EMULSIFIERS
               /SURFACTANTS
 OFF-SPECIFICATION
 PRODUCT
PACKAGING,
LABELING,
CONTAINER
TESTING &
STORAGE
>
f
                         FINAL
                         PACKAGES
                         PRODUCT
     Source: United States EPA, 1996
   III.D.2. Dry Formulating and Packaging
                     Dry formulations also contain active and inert ingredients. The final product
                     may be in many different forms, such as powders, dusts, granules, blocks,
                     solid objects impregnated with pesticide (e.g., flea collars), pesticides formed
                     into a solid shape (e.g., pressed tablets), microencapsulated dusts or granules
                     (AI coated with a polymeric membrane to prevent premature degradation), or
                     encapsulated water soluble packaging. They are formulated in various ways,
                     including:

                     •   mixing powdered or granular AIs with dry inert carriers;
                     •   spraying or mixing a liquid active ingredient onto a dry carrier;
                     •   soaking or using pressure and heat to force active ingredients into a solid
                        matrix;
                     •   mixing active ingredients with a monomer and allowing the mixture to
                        polymerize into a solid; and
                     •   drying or hardening an active ingredient solution into a solid form.

                     These dry pesticide products may be designed to be applied in solid form or
                     dissolved or emulsified in water or solvent prior to application (USEPA,
                     1996).

                     Because there are many types of dry pesticide products,  dry pesticide
                     formulating lines can vary considerably. In general, though, dry formulating
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                    lines have tanks or containers to hold the active ingredients and inert raw
                    materials, and may include mixing tanks,  ribbon  blenders, extruding
                    equipment, high pressure and temperature tanks for impregnating solids with
                    active Ingredient, vacuums or other types of drying equipment, tanks or bins
                    for storage of the formulated pesticide product, pelletizers, presses, milling
                    equipment, sieves, and sifters (USEPA, 1996).

                    Raw materials for dry pesticide products may be liquid or solid. Liquid raw
                    materials may be stored in rail tank cars, tank trucks, minibulks, drums, or
                    bottles. Dry raw materials may be stored in silos, rail cars, tank trucks,
                    minibulks, metal drums, fiber drums, bags, or boxes. Liquid raw materials
                    may be pumped, poured or sprayed into formulation vessels, while dry raw
                    materials are  frequently transferred  to formulation equipment by screw
                    conveyors (consisting of a helix mounted on a shaft and turning in a trough),
                    elevators, or by pouring.

                    Dry formulating lines may also include piping and pumps to move raw
                    materials from storage tanks to the formulation equipment, and  to move
                    formulated pesticide product to the packaging equipment. Other items that
                    may be included in the dry pesticide product line are premixing tanks, tanks
                    for  storing  formulated  product  prior to packaging,  stirrers,  heaters,
                    refrigeration units on formulation and  storage equipment, scales, and air
                    pollution control equipment (e.g., cyclones, filters, or baghouses) (USEPA,
                    1996).

                    Dry pesticide products may be packaged into rail tank cars, tank trucks, totes,
                    and minibulks, but are typically packaged into bags, boxes, and drums. As
                    with many liquid formulations, dry formulations are packaged by simply
                    transferring the final product into boxes, drums, jugs, or bags.  Small
                    quantities or bags are typically packaged manually using a gravity feed from
                    the formulating unit into the containers or bags. Larger quantities may be
                    packaged on an automated line,ssimilar to liquid packaging lines.

                    Figure 17 illustrates a dry pesticide formulation line.
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   Figure 17: Typical Process for Dry Formulating
     RAW MATERIAL DRUM
     /BAG/TOTE TANK
      DRY PESTICIDE
      ACTIVE
      INGREDIENT
                                                        DRY INERT
                                                        INGREDIENTS
                                       DRY
                                       CARRIER
                                       INERT
                                        ATER1AL
       LIQUID
       PESTICIDE
       ACTIVE
       INGREDIENT
RAW MATERIAL DRUM
/BULK TANK
     FINAL
     PACKAGED!
     PRODUCT
     Source: United States EPA, 1996
       III.D.3. Aerosol Packaging
                    Some pesticide products (typically water-based or solvent-based liquids) are
                    packaged as aerosols, which can be applied to surfaces or dispersed in the air.
                    The product is placed in spray cans that are put under pressure and a
                    propellant is added, which forces the product out of the can in an aerosol
                    spray.  An aerosol packaging line typically includes a filler, a capper, a
                    propellant injector, and a United States Department of Transportation (DOT)
                    test bath. In the filler, formulated pesticide product is dispensed into empty
                    aerosol cans, in much the same way as the liquid packaging lines fill
                    containers. The cans are then sent to the capper, where a cap with a nozzle is
                    placed on the can.  The can enters a separate room, where the propellent is
                    injected into the can, a vacuum is pulled, and the cap is crimped to make the
                    can airtight. In order to comply with DOT regulations on the transport of
                    pressurized  containers, each can must then be tested for leaks and rupturing
                    in a DOT test bath. Test baths indicate leaks by the appearance of bubbles
                    at the point of leakage on the cylinder.  The aerosol packaging line may also
                    include a can washer to remove residue from can exteriors prior to entering
                    the test bath (to reduce contaminant buildup in the bath), a dryer to dry can
                    exteriors, and machinery to package aerosol cans into boxes for shipment
                    (USEPA, 1996).
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       IILD.4. Pressurized Gas Formulating and Packaging

                     Some pesticide products are formulated and packaged as pressurized gases,
                     primarily for the purpose of soil fumigation.  Soil fumigation is used where
                     the nematodic and fungal populations in soil  prohibit successful seed
                     planting.  Volatile  general toxicants, such as  low molecular weight
                     halogenated compounds, are typically injected into the soil before planting,
                     but are also  occasionally  used once plants have reached maturity (Kent,
                     1992).

                     The active and inert ingredients are received as liquid, pressurized liquids, or
                     gases, and are stored in tanks, tank trucks, rail cars, or minibulk storage
                     containers. Liquid ingredients are  placed  in  a holding  tank  prior to
                     formulation. Formulating and packaging operations for these products usually
                     occurs in one step in a closed-loop system. The ingredients are metered by
                     weight through  pressurized  transfer lines into  DOT-approved  steel
                     application cylinders. Other equipment that may be included in a pressurized
                     gas line include pump and piping, and heating and refrigerating units to
                     maintain gas pressures and temperatures in storage (USEPA, 1996).

                     The cylinders may be refilled at a later date, after they have been tested to
                     ensure that they  are still  capable  of containing pressurized fluids.  DOT
                     requires hydrostatic pressure testing, as well as visual examination of the
                     cylinder (USEPA, 1996).

   III.D.5. Repackaging

                     Repackaging operations are similar to packaging operations, except the "raw
                     material" is an already formulated product that has been packaged for sale.
                     Repackagers  often purchase formulated  pesticide products,  transfer the
                     product to new containers with customer-specific labeling, and sell them to
                     distributors (USEPA, 1996).

                     A separate type of repackaging, called refilling, is usually performed by
                     agrichemical facilities that transfer pesticide products from bulk storage tanks
                     into minibulks. These refillable containers are typically constructed of plastic
                     and typically have capacities ranging from 100 to 500 gallons. Minibulks may
                     be owned by the refilling establishment, the pesticide registrant, or by the end
                     user.  Production lines usually consist of a bulk storage tank, a minibulk tank
                     into which the product is repackaged, and any  interconnecting  hoses or
                     piping. The bulk storage tanks may be dedicated by product and  clustered
                     together in a diked area. The products are dispensed to the minibulks by the
                     use of manual system or a computer-regulated system of pumps and meters
                     (USEPA, 1996).
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III.E.  Raw Material Inputs and Pollution Outputs
                     Raw material inputs and pollution outputs of fertilizer products and pesticide
                     products differ considerably, and, therefore, are discussed separately below.
                     The pollution outputs are discussed both specifically by product as well as
                     generally by process since there are some similarities in the fertilizer and
                     pesticide production processes and pollutant outputs.
       III.E.1. Fertilizers
                     The primary raw materials for fertilizer manufacturing are phosphate rock,
                     natural gas, sulfuric acid, and carbon dioxide. These materials are combined
                     by  several methods and in different proportions to produce  a variety of
                     fertilizer products, as described in section III.

                     Figure 18 summarizes the fertilizer material inputs for the principal fertilizer
                     products.
               Figure 18: Raw Material Flowchart for Principal Fertilizer Materials
                Source: Adapted from Manual on Fertilizer Statistics, Food and Agriculture Organization of the
                United Nations, Rome 1991.
                     Because the basic fertilizer nutrients are found in many natural and manmade
                     materials, raw materials for fertilizers can also be derived from sources other
                     than the virgin materials described above.  Common sources of fertilizer
                     ingredients are sewerage treatment sludges and certain industrial wastes.
                     Although these waste-derived fertilizers may  contain essentially the same
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                     nutrients as fertilizers derived from virgin materials, they also may contain
                     additional constituents that were present in the waste material and which may
                     not be beneficial, or are potentially harmful to crops, human health, or the
                     environment. Such constituents may enter the food chain or groundwater and
                     could become concentrated in the soil after repeated use. Lead, cadmium and
                     arsenic are some of the more common fertilizer ingredients that could be
                     harmful if sufficient quantities are present. It should be noted, however, that
                     fertilizers derived from virgin materials also have the potential to contain
                     harmful levels  of these constituents if significant quantities are naturally
                     present in the raw materials.

                     One waste material input which has  received some attention recently is
                     cement kiln dust (CKD). Although there has been a considerable amount of
                     research conducted on CKD use as a fertilizer, existing applications of CKD
                     for this purpose  have been mostly anecdotal,  and there  is only limited
                     evidence that commercial CKD use as a fertilizer is growing significantly
                     (USEPA, 1993b).

                     Like agricultural lime, CKD is alkaline and contains a number of essential
                     plant nutrients.  Because of these parallel characteristics, CKD has been used
                     as an agricultural soil amendment. CKD possesses significant fertilizer
                     potential, particularly because of its high potassium content. Soil scientists
                     have also suggested that other key plant nutrients contained in CKD, such as
                     calcium, phosphorous,  and  zinc, might be  beneficial  in  some fertilizer
                     applications. However, some concern has been raised over hazardous wastes
                     in CKD (USEPA, 1993b).

                     Coal combustion by-products are also receiving attention for their potential
                     agricultural benefits., including alleviating soil trace elemental deficiencies,
                     modifying soil pH, and increasing levels of Ca and S, infiltration rates, depth
                     of rooting, and  drought tolerance. Flue gas desulfurization residues, which
                     contain gypsum, have the potential to improve water use efficiency, product
                     quality, and productivity of soil-crop systems.  The short term benefits of coal
                     combustion by-products usage has been demonstrated, however,  long term
                     effects have not been documented. Future hazards and benefits are yet to be
                     determined  (Korcak, 1995).  Electric-arc furnace dust  is also used as a
                     fertilizer ingredient since it contains a number of trace elements required by
                     plants, including zinc.

                     Pollution outputs are summarized in terms of air emission, wastewater, and
                     residual wastes.

                     Air Emissions

                     Synthetic Ammonia
                     Air pollutants from the manufacture of synthetic anhydrous ammonia are
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                    emitted primarily from four process steps:

                           •   regeneration of the desulfurization bed,
                           •   heating of the catalytic steam,
                           •   regeneration of carbon dioxide scrubbing solution,
                           •   steam stripping of process condensate.

                    More than 95 percent  of the ammonia plants in the United  States use
                    activated  carbon fortified with metallic  oxide additives  for feedstock
                    desulfurization. Vented regeneration steam contains sulfur oxides (SOX) and
                    hydrogen sulfide (H2S), depending on the amount of oxygen in the steam.
                    Regeneration may also emit hydrocarbons and carbon monoxide (CO). The
                    reformer, heated with natural gas or fuel oil, may emit combustion products
                    such as NOX, CO, SOX, hydrocarbons, and particulates (USEPA, 1993a).

                    Carbon dioxide (CO2) is removed from the synthesis gas by scrubbing with
                    monoethanolamine (C2H4NH2OH) or  hot potassium carbonate solution.
                    Regeneration of this CO2 scrubbing solution with steam produces emissions
                    of water, NH3, CO, CO2 and monoethanolamine (USEPA,  1993a).

                    Cooling the synthesis gas after low temperature shift conversion forms a
                    condensate containing NH3, CO2, methanol (CH3OH), and trace  metals.
                    Condensate steam strippers are used to remove NH3 and methanol from the
                    water, and steam from this may be vented to the atmosphere, emitting NH3,
                    CO2, and methanol (USEPA, 1993a).

                    Nitric Acid
                    Emissions from nitric acid manufacturing consist primarily of NO and NO2
                    (which account for visible emissions), and trace amounts of HNO3 mist and
                    NH3.  The major source of nitrogen oxides  is the tail gas  from the acid
                    absorption tower. In general, the quantity of nitrogen oxides (NOX) emissions
                    is directly related to the kinetics of the nitric acid formation reaction and
                    absorption tower design. NOX emissions can increase when there is:

                           •   insufficient air supply to the oxidizer and absorber,
                           •   low pressure, especially in the absorber,
                           •   high temperatures in the cooler/condenser and absorber,
                           •   production of an excessively high-strength product acid,
                           •   operation at high throughput rates,
                           •   faulty equipment such as compressors or pumps which lead to
                              lower pressures, leaks, and reduced plant efficiency (USEPA,
                               1993a).

                    Comparatively small amounts of nitrogen oxides are also  lost from acid
                    concentrating plants. These losses (mostly NO2) are from  the condenser
                    system, but the  emissions  are small  enough to  be controlled easily by
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                     absorbers.

                     Acid mist emissions do not occur from the tail gas of a properly operated
                     plant. The small amounts that may be present in the absorber exit gas streams
                     are typically removed by a separator or collector prior to entering the catalytic
                     reduction unit or expander.

                     The acid production system and storage tanks can be a significant source of
                     visible NOx emissions at nitric acid plants. Emissions from acid storage tanks
                     are most likely to occur during tank filling (USEPA, 1993a).

                     Ammonium Nitrate
                     The primary air emissions from ammonium nitrate production plants are
                     particulate matter (ammonium nitrate and coating materials), ammonia and
                     nitric acid. Ammonia and nitric acid are emitted primarily from solution
                     formation and granulators. Particulate matter (largely as ammonium nitrate)
                     can be emitted from most of the process operations (USEPA, 1993a).

                     The emission sources in solution formation and concentration processes are
                     neutralizers and evaporators, emitting nitric acid and ammonia. The vapor
                     stream off the top of the neutralization reactor is primarily steam with some
                     ammonia and NH4NO3 particulates  present. Specific plant operating
                     characteristics, however, make these emissions vary depending upon use of
                     excess ammonia or acid in the neutralizer. Particulate emissions from these
                     operations tend to be smaller in size than those from solids production and
                     handling processes and generally are recycled back to the process (USEPA,
                     1993a).

                     Emissions from solids formation processes are ammonium nitrate particulate
                     matter and ammonia. The sources of primary importance are prill towers (for
                     high density and low density prills) and granulators (rotary drum and pan).
                     Emissions from prill towers result from carryover of fine particles and fume
                     by the prill cooling air flowing through the tower. These fine particles are
                     from microprill formation, attrition of prills colliding with the tower or one
                     another, and rapid transition of the ammonia nitrate between crystal states
                     (USEPA, 1993a).

                     Microprill formation resulting from partially plugged orifices of melt spray
                     devices can  increase fine  dust  loading and emissions. Certain  designs
                     (spinning buckets)  and practices (vibration of spray plates) help  reduce
                     plugged orifices and thus microprill formation. High ambient air temperatures
                     can cause increased emissions because of entrainment as a result of higher air
                     flow required to cool prills and because of increased fume formation at the
                     higher temperatures (USEPA, 1993a).

                     Emissions from screening operations are generated by the attrition of the
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                    ammonium nitrate solids against the screens and against one another. Almost
                    all  screening operations  used in the ammonium nitrate manufacturing
                    industry are enclosed or have a cover over the uppermost screen. Emissions
                    are ducted from the process for recovery or reuse (USEPA, 1993a).

                    Bagging and bulk  loading operations are  also a  source  of particulate
                    emissions. Dust is emitted from each type of bagging process during final
                    filling when dust laden air is displaced from the bag by the ammonium
                    nitrate. The potential for emissions during bagging is greater for coated than
                    for uncoated material. It is expected that emissions from bagging operations
                    are primarily the kaolin, talc or diatomaceous earth coating matter. About 90
                    percent of solid ammonium nitrate produced domestically is bulk loaded.
                    While particulate emissions from bulk loading are not generally controlled,
                    visible emissions are within typical state regulatory requirements (below 20
                    percent opacity) (USEPA, 1993a).

                    Urea
                    Emissions from urea manufacture are mainly ammonia and particulate matter.
                    Formaldehyde and methanol, hazardous air pollutants,  may be emitted if
                    additives are used. Formalin™, used as a formaldehyde additive, may contain
                    up to 15 percent methanol. Ammonia is emitted during the solution synthesis
                    and solids production processes. Particulate matter is emitted during all urea
                    processes (USEPA, 1993a).

                    In the synthesis process, some emission control is inherent in the recycle
                    process where carbamate gases and/or liquids are recovered and recycled.
                    Typical  emission  sources from  the  solution  synthesis  process  are
                    noncondensable vent streams from ammonium carbamate decomposers and
                    separators. Emissions from synthesis processes are generally combined with
                    emissions from the solution concentration process and are vented through a
                    common stack. Combined particulate emissions from urea synthesis and
                    concentration operations are small compared to particulate emissions from
                    a typical solids-producing urea plant.  The synthesis  and concentration
                    operations are usually uncontrolled except for recycle provisions to recover
                    ammonia (USEPA, 1993a).

                    Uncontrolled emission rates from prill  towers may be affected by  the
                    following factors:
                           •     product grade being produced
                           •     air flow rate through the tower
                           •     type of tower bed
                           •     ambient temperature and humidity  (USEPA, 1993 a)

                    The total of mass emissions per unit  is usually lower for feed grade prill
                    production than for agricultural grade prills, due to lower airflows.
                    Uncontrolled particulate emission rates for fluidized bed prill towers  are
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                    higher than those for nonfluidized bed prill towers making agricultural grade
                    prills, and are approximately equal to those for nonfiuidized bed feed grade
                    prills (USEPA, 1993a).

                    Ambient air conditions can affect prill tower emissions.  Available data
                    indicate that colder temperatures promote the formation of smaller particles
                    in the prill  tower exhaust.  Since smaller particles are more difficult to
                    remove, the efficiency of prill tower control devices tends to decrease with
                    ambient temperatures. This can lead to higher emission levels for prill towers
                    operated during cold weather. Ambient humidity can also affect prill tower
                    emissions. Air flow rates must be increased with high humidity, and higher
                    air flow rates usually cause higher emissions (USEPA, 1993 a).

                    In the solids screening process, dust is generated by abrasion of urea particles
                    and the vibration of the  screening mechanisms.  Therefore, almost all
                    screening operations used in the urea manufacturing industry are enclosed or
                    are covered over the uppermost screen.  Emissions attributable to  coating
                    include entrained clay dust from loading, inplant transfer, and leaks from the
                    seals of the coater (USEPA, 1993a).

                    Phosphoric Acid
                    Gaseous fluorides such as silicon tetrafluoride (SiF4) and hydrogen fluoride
                    (HF) can be major emissions from wet process acid production. Phosphate
                    rock contains 3.5 to 4.0 percent fluorine. Part of the fluorine from the rock is
                    precipitated with the gypsum, another part is leached out with the phosphoric
                    acid product, and the remaining portion  is vaporized in the reactor or
                    evaporator. The relative quantities of fluorides in the filter acid and gypsum
                    depend on the type of rock and the operating conditions. Final disposition of
                    the volatilized  fluoride depends on the design and operation of the plant
                    (USEPA, 1993a).

                    The reactor in which phosphate rock is reacted with sulfuric acid is the main
                    source of emissions. Fluoride emissions accompany the  air used to cool the
                    reactor slurry. Vacuum flash cooling has replaced the air cooling method to
                    a large extent, since emissions are minimized in the closed system.

                    Acid concentration by evaporation is another source of fluoride emissions.
                    Approximately 20 to 40 percent of the fluorine originally present in the rock
                    vaporizes in this operation. Particulate matter containing fluorides can be
                    emitted directly from process equipment. About three to six percent of the
                    particulates can be fluorides, as measured at one facility (USEPA, 1993a).

                    Ammonium Phosphates
                    The major  sources of air emissions from  the production of ammonium
                    phosphatic fertilizers include the reactor, the ammoniator-granulator, the
                    dryer and cooler, product sizing and material transfer, and the gypsum pond.
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                    The reactor and ammoniator-granulator, produce   emissions  of gaseous
                    ammonia, gaseous fluorides such as hydrogen fluoride (HF)  and silicon
                    tetrafluoride (SiF4),  and particulate  ammonium phosphates.  These two
                    exhaust streams are generally combined and passed through primary and
                    secondary scrubbers (USEPA, 1993a).

                    Exhaust gases from the dryer and cooler also contain ammonia, fluorides and
                    particulates, and these streams are commonly combined and passed through
                    cyclones and primary and secondary scrubbers. Particulate emissions and low
                    levels of ammonia and fluorides from product sizing and material transfer
                    operations are controlled the same way (USEPA, 1993a).

                    Normal Superphosphates
                    Sources of emissions at a normal  superphosphate plant  include  rock
                    unloading and feeding, mixing operations (in the reactor), storage (in the
                    curing building), and fertilizer handling operations. Rock unloading, handling
                    and feeding generate particulate emissions of phosphate rock dust. The mixer,
                    den and curing building emit gases in the form of silicon tetrafluoride (SiF4),
                    hydrogen fluoride (F£F) and particulates composed of fluoride and phosphate
                    material (USEPA, 1993a).

                    Triple Superphosphates
                    Emissions  of fluorine compounds and dust  particles  occur  during the
                    production of granulated triple superphosphate. Silicon tetrafluoride (SiF4)
                    and hydrogen fluoride (HF) are released by the acidulation reaction and they
                    evolve from the reactors, den, granulator, and dryer. Evolution of fluoride is
                    essentially finished in the dryer and there is little fluoride evolved from the
                    storage pile in the curing building (USEPA, 1993a).

                    Sources of particulate emissions include the reactor, granulator, dryer,
                    screens, cooler, mills, and transfer conveyors.  Additional  emissions  of
                    particulate  result from the unloading,  grinding, storage,  and  transfer  of
                    ground phosphate rock. Facilities may also use limestone, which is received
                    in granulated form and does not require additional milling (USEPA, 1993a).

                    Wastewater

                    Wastewater from the fertilizer industry can be classified into four  groups:
                                process effluents resulting from contact with gas, liquids, or
                                solids
                                dedicated effluents which may be separated for use in one
                                process or for recycling at a controlled rate
                                effluents from general services such as cleaning or pretreatment
                                occasional effluents such as leaks or spills
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                    A number of process wastewater streams from the nitrogenous fertilizer
                    industry have been identified.  Frequently these wastewaters contain high
                    levels of nitrogenous compounds such as ammonia, nitrates, and organic
                    nitrogen.  In ammonia production, wastewater is generated from process
                    condensate stripping. Ammonium nitrate manufacturing produces process
                    wastewater in the neutralization process, the evaporation unit, and air cooling
                    equipment. The vacuum condenser in urea plants is a source of wastewater.
                    Most scrubbing operations are also a source of wastewater. Nitric acid
                    production generates relatively little wastewater since there is no process
                    wastewater source. Steam generated in nitrogenous fertilizer processing may
                    contain dissolved and suspended solids, alkalinity, and hardness (USEPA,
                    1974).

                    The most common methods for removing nitrogenous  compounds include:

                           •     Biological nitrification/denitrification
                           •     Air or steam stripping
                           •     Ion exchange
                           •     Breakpoint  chlorination (Water Environment  Federation,
                                 1994).
                     The major source of wastewater from any phosphatic fertilizer manufacturing
                     process is referred to as "pond water." Phosphoric acid production creates
                     large quantities of pond water for cooling of the process, concentration of the
                     product and for processing and storage of the gypsum byproduct. Gypsum
                     slurry water is decanted from the top of the gypsum stacks and sent to the
                     cooling  pond  through collection ditches  (USEPA,  1993a).   Through
                     evaporation and recycling, contaminant concentrations in pond water can
                     reach  several grams  per liter  of phosphates  and  fluoride.  Additional
                     elemental contaminants in pond water which originate in phosphate rock are
                     arsenic, cadmium, uranium, vanadium, and radium (USEPA, 1974).

                     The most common industry treatment for removing phosphorous is lime
                     neutralization and settling.

                     Occasional wastewater is generated in any fertilizer production facility by
                     leaks, spills, cleaning, maintenance, and laboratory tests. Cleaning of cooling
                     and pollution control systems also produces process wastewater.  Cooling
                     water may contain ammonia, sulfate, chloride, phosphate, chromate, and
                     dissolved solids which become concentrated through evaporation (USEPA,
                     1974). The laundry of workers' clothing is another source  of wastewater
                     originating outside the actual process.

                     Solid/Hazardous/Residual Wastes
                     One of the largest solid wastes in the fertilizer industry is phosphogypsum
                     which is produced during phosphoric acid production. Approximately 1.5
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                    tons of phosphogypsum is produced per ton of phosphate rock fed, or 5 tons
                    per ton of phosphoric acid produced (expressed as P2O5). Gypsum (calcium
                    sulphate dihydrate) is a mineral which also occurs in nature. Phosphogypsum
                    is produced by the reaction of phosphate rock with sulphuric acid during the
                    process of producing phosphoric acid.  The term "phosphogypsum" is used
                    to  specify the particular gypsum arising from the acidulation of phosphate
                    rock, because it contains trace amounts of many of the mineral impurities that
                    accompany phosphate rock.  One of these impurities is radium, the parent of
                    radon.  Other trace  impurities found in phosphogypsum include arsenic,
                    nickel, cadmium,  lead, aluminum, fluoride, and phosphoric acid.  Mainly
                    because of the radium content, the EPA restricts use of phosphogypsum and
                    stipulates that no phosphogypsum with radium over ten pCi/g can be
                    removed from the stacks adjacent to the agricultural chemical plants (UNEP,
                    1996).

                    The use  of waste phosphogypsum for  other purposes has been widely
                    encouraged, but economic and/or quality problems and/or the demand for the
                    resulting products frequently inhibit or prevent this. These problems relate
                    not only to the impurities in the gypsum, but  also to its relatively high
                    moisture content. Plasterboard, plaster, and cement are the main possibilities.
                    It is also possible  to recycle phosphogypsum in sulphuric acid production.
                    The ready availability of natural gypsum and the high cost of gypsum-based
                    sulphuric acid, as  well as the presence of trace contaminants, are the main
                    obstacles to its use (Miller, 1995).  However, in countries where gypsum and
                    other  sulphurous  raw materials  are  scarce, phosphogypsum has  been
                    successfully used for these purposes (UNEP, 1996).

                    Dumping gypsum on land is not possible everywhere because the material
                    settles and  dries slowly  and requires an adequate land area and certain
                    climatic and soil conditions where the stack is situated.  Gypsum stacks are
                    being increasingly regulated in terms of lining and cap systems to prevent
                    contaminated leaching or runoff (UNEP, 1996).

                    All phosphate ores contain traces  of radioactive elements and a number of
                    metals. During processing, these are partitioned between beneficiation
                    process wastes, the waste from the further processing into intermediate and
                    finished fertilizer production, and  some end up in the final product (UNEP,
                    1996).

                    Cadmium is a heavy metal which accumulates  in living systems and can
                    become toxic above certain limits. The quantity of cadmium contained in a
                    phosphatic fertilizer depends on the source of the rock or waste material from
                    which it was made.  The cadmium content of phosphate rocks varies from
                    almost zero to over 300 mg/kg P2O5. The acidulation of phosphate rock
                    partitions the cadmium between the fertilizer product and the by-products,
                    mainly the phosphogypsum arising from phosphoric acid production (UNEP,
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                     1996).

                     The fertilizer industry has for some  decades tried to  develop cadmium
                     separation processes. Processes studied so far have shown serious limitations
                     and problems,  with regard  to  safety,  cost, energy consumption  or
                     environmental concerns. Currently available processes are expensive and are
                     not economically viable except for phosphates destined for human or animal
                     consumption, which have a greater added value.  A process developed for
                     removing cadmium from phosphoric acid, which is used in the production of
                     many phosphatic fertilizers (except normal superphosphate), has shown
                     promise on a laboratory scale, but needs further testing before being used on
                     an industrial scale (UNEP, 1996).

                     Off-specification product, spills,  and  dusts collected in emission control
                     systems are potential sources of residual wastes. Products are occasionally
                     suspended or canceled, leaving stockpiles of residual product. Other possible
                     sources of solid wastes are spent catalysts, spent containers, wastewater
                     treatment sludges, and spent filters. Many of these wastes  are transported off-
                     site for disposal.   However, with good  housekeeping  techniques and
                     dedicated systems, some of these wastes  may be  recycled back into the
                     process instead of being wasted.

                     Catalysts used in the steam reforming process need to be  replaced every two
                     to six years. Spent catalysts contain oxides of hexavalent chromium, zinc,
                     iron, and nickel. They are typically returned to the manufacturer or other
                     metal recovery companies for recycling and reclamation of valuable materials
                     (UNEP, 1996).

       III.E.2. Pesticide Formulating, Packaging, and Repackaging

                     As listed below, input raw materials  include the pesticide concentrates from
                     pesticide  manufacturing plants as  well as diluents and  other chemical
                     additives used in the formulating process:

                     •   Active Ingredients
                            Organic/inorganic pesticides: insecticides, herbicides, fungicides, and
                            others. (See Table 10.)

                     •   Formulation and preparation materials
                            Dry formulations:
                               organic   flours,  sulfur,  silicon  oxide,  lime,   gypsum,  talc,
                               pyrophyllite, bentonites,  kaolins, attapulgite, and volcanic ash.

                            Liquid formulations:
                                  Solvents: xylenes,  kerosenes, methyl isobutyl ketone,  amyl
                                  acetate, and chlorinated solvents.
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                                  Propellants: carbon dioxide and nitrogen.
                                  Others:  wetting  and dispersing agents,  masking  agents,
                                  deodorants, and emulsifiers (USEPA, 1990).

                    In addition to pesticide materials, some facilities listed under SIC code 2879
                    produce fertilizer/pesticide blends. A variety of nitrogenous, phosphatic, and
                    mixed fertilizers may be inputted into bulk blending tanks to produce these
                    combinations.
Table 10: Approximate Quantities of Most Commonly Used Conventional
Pesticides in United States Agricultural Crop Production
Chemical
Atrazine
Metolachlor
Metam Sodium
Methyl Bromide
Dichloropropene
2,4-D
Glyphosate
Cyanazine
Pendimethalin
Trifluralin
Acetochlor
Alachlor
EPTC
1995 Consumption
(Million pounds
active ingredient)
68-73
59-64
449-54
39-46
38-43
31-36
25-30
24-29
23-28
23-28
22-27
19-24
9-13
Chemical
Chlorpyrifos
Chlorothalonil
Copper Hydroxide
Propanil
Dicamba
Terbufos
Mancozeb
Fluometuron
MSMA
Bentazone
Parathion
Sodium Chlorate

1995 Consumption
(Million pounds
active ingredient)
9-13
8-12
7-11
6-10
6-10
6-9
6-9
5-9
4-8
4-8
4-7
4-6

Source: Pesticide Industry Sales and Usage, 1994 and 1995 Market Estimates, EPA, August 1997.
                     Air Emissions

                     Air emissions can be generated throughout the pesticide formulating and
                     packaging processes, mostly when fine particulates of pesticide dust become
                     suspended in air while the materials are being moved, processed, or stored.
                     Most dust or granule blending mills are equipped with vacuum  systems,
                     cyclones, and wet scrubbers to collect fugitive dust. Some vacuum systems
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                    are dedicated to certain processes to facilitate reuse of the dust. Other systems
                    are used to  collect dust from a number of areas  (USEPA, 1990).  Dust
                    generated by pesticide formulation processes contain AIs which may be toxic
                    to humans and the environment. Thus, they are important to contain.

                    Volatile organic compound (VOC) emissions such as xylene may also arise
                    when solvent-based liquid formulations are produced. VOC emissions may
                    also be generated during equipment cleaning with solvents.

                    Wastewater

                    Process wastewater is defined in 40 CFR 122.2 as "any water which, during
                    manufacturing or processing, comes into direct contact with or results from
                    the production or use of any raw material, byproduct, intermediate product,
                    finished  product, or waste product."  Wastewater from "the  pesticide
                    formulating  industry is  typically due to cleaning of equipment and related
                    process areas and not the actual formulating processes (USEPA, 1996).

                    Cleaning and decontaminating blending and liquid pesticide mixing and
                    storage equipment generates pesticide-contaminated wastewater or solvent,
                    depending upon whether the equipment is used to formulate water or solvent-
                    based pesticides. Decontamination is performed between batches of different
                    types of formulations to prevent cross contamination of the subsequent batch.
                    Decontamination is also performed prior to taking the equipment out of
                    service for maintenance. The decontamination is commonly performed using
                    high pressure  water hoses equipped  with spray nozzles, portable steam
                    generators, or by running  a  batch  of solvent through the formulating
                    equipment (USEPA, 1990).

                    Active  ingredient containers,  such  as  5 5-gallon  drums,  are  often
                    decontaminated by triple rinsing. The decontamination is usually performed
                    using a high pressure water hose equipped with a spray nozzle or a portable
                    steam jenny. " The containers can then be sold or given  to commercial
                    recycling firms, depending on label directions (USEPA, 1990).

                    Floor, wall,  and equipment exterior washing  is  typically performed using
                    water hoses equipped with spray nozzles. It may also involve the use of mops
                    and squeegees. Wastewater is also generated by clean-up of spills and leaks.

                    Wastewater  from these operations  typically contains AIs, solvents, and
                    wetting agents (USEPA, 1990). Other sources of wastewater include:

                           •   Pollution control scrubber water
                           •   Department  of Transportation leak test water
                           •   Safety equipment wash water
                           •   Laboratory equipment wash water
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                           •  Shower water
                           •  Laundry water
                           •  Fire protection test water
                           •  Contaminated precipitation runoff (USEPA, 1996)

                    Solid/Hazardous/Residual Wastes

                    Residual  wastes include  containers and container liners  potentially
                    contaminated with pesticides, as well as off-spec product, dust collected from
                    emission control equipment, and product spills.  Contaminated laboratory
                    equipment and protective workers clothing are other potential  solid waste
                    sources (USEPA, 1990).

                    Decontamination of the solid-based pesticide blending mills may generate
                    solid diluent contaminated with pesticides. The diluent typically consists of
                    clay for dust mills and sand for granule mills (USEPA, 1990).

                    In case of pesticide products which have been suspended or canceled, there
                    may be existing stocks of these products remaining. EPA may allow the use
                    of existing stocks or prohibit such  use.  State environmental agencies
                    occasionally collect unusable pesticides.

                    Procedures for pesticide management have been proposed by  EPA, as
                    authorized under section  19 of the  Federal Insecticide, Fungicide,  and
                    Rodenticide Act (FIFRA). For more details, refer to section VI.C on pending
                    and proposed regulatory requirements.
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Table 11: Summary of Potential Pollution Outputs for the Agricultural
Chemical Industry
Process
Nitric Acid
Absorption Tower
Solution
Formulation and
Granulation
Solids Formation
Regeneration of
Desulfurization
and Filter Beds
Screening
Wet Process
Phosphoric Acid
Production
Unloading of
materials into
blending tanks
Open processing
and storage
equipment
Equipment and
facility cleaning
Laboratory
procedures
Spills and runoff
Pollution control
systems
Air Emissions
NO, NO2, HNO3 in
tailgas
NH3, HNO3
particulates
Particulates, NOX,
SiF4, HF
Hydrocarbons, CO,
NH3, C02
Dust
SiF4, HF
Dust/particulates
released in transfer
VOC's
NA
VOC's and dusts
released
Dust/particulates
released by spill
NA
Process Wastewater
NA
Condensed steam with
NH4NO3andNH3
NA
Condensed steam, NH3,
CO2
NA
Pond water
NA
NA
Washwater, waste
solvent
Washwater, lab testing
water
Contaminated
rainfall/runoff
Contaminated scrubber
water
Residual Waste
Spent tower
materials, trays
NA
Dusts
Spent bed material
Mixed undersized
captured dusts, used
screens
Gypsum
Leftover raw material
containers
NA
Waste sands and
clays, used mops/
squeegees/etc.
Off-spec product used
for testing/analysis
Contaminated solid
product
Spent filter material
Source: Guide to Pollution Prevention, The Pesticide Formulating Industry, Center for
Environmental Research Information, United States EPA, Washington D.C., 1990.
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III.F. Management of Chemicals in Wastestream
       Fertilizers
                    The Pollution Prevention Act of 1990 (PPA) requires facilities to report
                    information about the management of Toxic  Release  Inventory (TRI)
                    chemicals in waste and efforts made to eliminate or reduce those quantities.
                    These data have been collected annually in section 8 of the TRI reporting
                    Form R beginning with the 1991 reporting year. The data summarized below
                    cover the years 1995-1998 and are meant to provide a basic understanding of
                    the quantities of waste handled by the industry, the methods typically used to
                    manage  this waste, and recent trends in these methods.   TRI waste
                    management data can be used to assess trends in  source reduction within
                    individual industries and facilities, and for specific TRI chemicals.  This
                    information could then be used as a tool in identifying opportunities for
                    pollution prevention or compliance assistance activities.

                    While the quantities reported for 1995 and 1996 are estimates of quantities
                    already managed, the quantities listed by facilities for 1997 and 1998 are
                    projections only. The PPA requires these projections to encourage facilities
                    to consider future source reduction, not to establish any mandatory limits.
                    Future-year estimates are not commitments that facilities reporting under TRI
                    are required to meet.
                     Table 12 shows that the TRI reporting fertilizer manufacturing and mixing
                     facilities managed about 566 million pounds of production related wastes
                     (total  quantity of TRI  chemicals in  the waste  from routine production
                     operations in column B) in 1996. From the yearly data presented in column
                     B, the total quantity of production related TRI wastes decreased between
                     1995 and 1996. Production related wastes are projected to increase in 1997
                     and 1998. Note that the affects of production increases and decreases on the
                     quantities of wastes generated are not evaluated here.

                     In 1996, about 84 percent of the industry's TRI wastes were managed on-site
                     through recycling, energy recovery, or treatment as shown in columns C, D,
                     and E, respectively. Most of these on-site managed wastes were recycled on-
                     site. There is a negligible amount (<1%) of wastes being transferred off-site
                     for recycling, energy recovery, or treatment. The remaining portion of the
                     production related wastes (12percentin 1995 and 16 percent in 1996), shown
                     in column I, is either released to the environment through direct discharges
                     to air, land, water, and underground injection,  or is transferred off-site for
                     disposal.
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Table 12: Source Reduction and Recycling Activity for the Fertilizer Industry as
Reported within TRI
A
Year
1995
1996
1997
1998
B
Quantity of
Production-
Related
Waste
(106lbs.)a
719
566
606
617
On-Site
C
%
Recycled
76%
77%
77%
78%
D
% Energy
Recovery
8%
1%
1%
1%
E
% Treated
4%
6%
7%
7%
Off-Site
F
%
Recycled
0%
0%
0%
0%
G
% Energy
Recovery
0%
0%
0%
0%
H
% Treated
0%
0%
0%
0%
I
% Released and
Disposed0 Off-
site
12%
16%
15%
14%
Source: 1996 Toxics Release Inventory Database.
a Within this industry sector, non-production related waste < 1% of production related wastes for 1996.
Total TRI transfers and releases as reported in section 5 and 6 of Form R as a percentage of production related
wastes.
Percentage of production related waste released to the environment and transferred off-site for disposal.
       Pesticides and Miscellaneous Agricultural Chemicals

                    Table  13 shows that the TRI reporting  pesticide and  miscellaneous
                    agricultural  chemicals facilities managed about 252 million pounds of
                    production related wastes (total quantity of TRI chemicals in the waste from
                    routine production operations in column B) in 1996.  From the yearly data
                    presented in column B, the total quantity of production related TRI wastes
                    increased between 1995 and 1996. Production related wastes were projected
                    to continue to increase in 1997 and 1998. Note that the affects of production
                    increases and decreases on the quantities  of wastes generated  are not
                    evaluated here.

                    In 1996, about 95 percent of the industry's TRI wastes were managed on-site
                    through recycling, energy recovery, or treatment as shown in columns C, D,
                    and E, respectively. Most of these on-site managed wastes were recycled on-
                    site. A small portion of the remaining wastes (4% in 1996) are transferred
                    off-site for recycling, energy recovery, or treatment.  The remaining one
                    percent of the production related wastes, shown in column I, is either released
                    to the environment  through direct discharges  to air, land, water,  and
                    underground injection, or is transferred off-site for disposal.
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Table 13: Source Reduction and Recycling Activity for the Pesticide and
Miscellaneous Agricultural Chemicals Industry as Reported within TRI
A
Year
1995
1996
1997
1998
B
Quantity of
Production-
Related
Waste
(106 lbs.)a
245
252
266
279
On-Site
C
%
Recycled
85%
84%
84%
85%
D
% Energy
Recovery
0%
0%
0%
0%
E
%
Treated
10%
11%
11%
11%
Off-Site
F
% Recycled
2%
2%
1%
1%
G
% Energy
Recovery
1%
1%
1%
1%
H
% Treated
1%
1%
2%
1%
I
% Released and
Disposed0 Off-
site
2%
1%
1%
1%
Source: 1996 Toxics Release Inventory Database.
a Within this industry sector, non-production related waste < 1% of production related wastes for 1996.
b Total TRI transfers and releases as reported in section 5 and 6 of Form R as a percentage of production related
wastes.
0 Percentage of production related waste released to the environment and transferred off-site for disposal.
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            Chemical Releases and Transfers
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            Chemical Releases and Transfers
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
                    This section is designed to provide background information on the pollutant
                    releases that are reported by this industry in correlation with other industries.
                    The best source of comparative pollutant release information is the Toxic
                    Release  Inventory  (TRI).   Pursuant to the Emergency  Planning and
                    Community Right-to-Know Act, TRI includes self-reported facility release
                    and transfer data for over 600 toxic chemicals. Facilities within SIC Codes
                    20 through 39 (manufacturing industries) that have more than 10 employees,
                    and that are above weight-based reporting thresholds are required to report
                    TRI on-site releases and off-site transfers. The information presented within
                    the sector notebooks is derived from the most recently available (1996) TRI
                    reporting year (which includes over 600 chemicals), and focuses primarily on
                    the on-site releases reported by each sector. Because TRI requires consistent
                    reporting regardless of sector, it is an excellent tool for drawing comparisons
                    across industries. TRI data provide the type, amount and media receptor of
                    each chemical released or transferred.

                    Although this sector notebook  does  not present historical information
                    regarding TRI chemical releases over time, please note that in general, toxic
                    chemical releases have been declining. In fact, according to the 1996 Toxic
                    Release Inventory Public Data Release, reported onsite releases of toxic
                    chemicals to the environment decreased by 5 percent (111.6 million pounds)
                    between 1995 and 1996 (not including chemicals added and removed from
                    the TRI chemical list during this period). Reported releases dropped by 48
                    percent between 1988 and 1996. Reported transfers of TRI chemicals to off-
                    site locations increased by 5 percent (14.3 million pounds) between 1995 and
                    1996. More detailed information can be obtained from EPA's annual Toxics
                    Release Inventory Public Data Release book (which is available through the
                    EPCRA Hotline  at 800-535-0202), or directly from the Toxic  Release
                    Inventory System database (for user support call 202-260-1531).

                    Wherever possible, the sector notebooks present TRI data as the  primary
                    indicator of chemical release within each industrial category.  TRI data
                    provide the type,  amount and media receptor of each chemical released or
                    transferred. When other sources of pollutant release data have been obtained,
                    these data have been included to augment the TRI information.
       TRI Data Limitations
                     Certain limitations exist regarding TRI data. Within some sectors, (e.g. dry
                     cleaning, printing and transportation equipment cleaning) the majority of
                     facilities are not subject to TRI reporting because they are not considered
                     manufacturing industries, or because they are below TRI reporting thresholds.
                     For these sectors, release information from other sources has been included.
                     In addition, many facilities report TRI more under than one  SIC code
 Sector Notebook Project
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Agricultural Chemical Industry
             Chemical Releases and Transfers
                     reflecting the multiple  operations carried out onsite whether or not the
                     operation is the facilities primary area of business as reported to the U.S.
                     Census Bureau. Reported chemicals are limited to the approximately 600
                     TRI chemicals.  A portion of the  emissions from agricultural chemical
                     facilities, therefore, are not captured by TRI. Also, reported releases and
                     transfers may or may not all be associated with the industrial operations
                     described in this notebook.

                     The reader should also be aware that TRI "pounds released" data presented
                     within the notebooks is not equivalent to a "risk" ranking for each industry.
                     Weighting each pound  of release equally does not factor in the relative
                     toxicity of each chemical that is released. The Agency is in the process of
                     developing an approach to assign toxicological weightings to each chemical
                     released so that one can differentiate between pollutants with significant
                     differences in toxicity.  As  a preliminary indicator of the environmental
                     impact of the industry's most commonly released chemicals, the notebook
                     briefly summarizes the toxicological properties of the top five chemicals (by
                     weight) reported by each industry.

       Definitions Associated With Section IV Data Tables

          General Definitions

                     SIC Code -- is the Standard Industrial Classification (SIC) code, a statistical
                     classification standard used for all establishment-based  federal economic
                     statistics. The SIC codes facilitate comparisons between facility and industry
                     data.

                     TRI Facilities — are manufacturing facilities that have 10 or more full-time
                     employees and are  above  established  chemical throughput thresholds.
                     Manufacturing facilities are defined  as facilities in Standard  Industrial
                     Classification primary codes 20-39.  Facilities must submit estimates for all
                     chemicals that are on the EPA's defined list and are above throughput
                     thresholds.

          Data Table Column Heading Definitions

                     The following definitions are based upon standard definitions developed by
                     EPA's Toxic Release Inventory Program. The categories below represent the
                     possible pollutant destinations that can be reported.

                     RELEASES — are on-site discharges of atoxic chemical to the environment.
                     This includes emissions to the air, discharges to bodies of water, releases at
                     the facility to land, as well as contained disposal into underground injection
                     wells.
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Agricultural Chemical Industry
             Chemical Releases and Transfers
                    Releases to Air  (Point and Fugitive Air Emissions) — include all air
                    emissions from industry activity. Point emissions occur through confined air
                    streams as found in stacks, vents, ducts, or pipes. Fugitive emissions include
                    equipment leaks, evaporative losses from surface impoundments and spills,
                    and releases from building ventilation systems.

                    Releases to Water (Surface Water Discharges) — encompass any releases
                    going directly to  streams, rivers, lakes, oceans, or other bodies of water.
                    Releases due to runoff, including storm water runoff, are also reportable to
                    TRI.

                    Releases to Land -- occur within the boundaries of the reporting facility.
                    Releases to land include  disposal of toxic chemicals in landfills,  land
                    treatment/application farming, surface impoundments, and other disposal on
                    land (such as spills, leaks, or waste piles).
                               i
                    Underground Injection -- is a contained release of a fluid into a subsurface
                    well for the purpose of waste disposal. Wastes containing TRI chemicals are
                    injected into either Class I wells or Class V wells. Class I wells are used to
                    inject liquid hazardous wastes or, dispose of industrial and  municipal
                    wastewaters beneath the lowermost underground source of drinking water.
                    Class V wells are  generally used to inject non-hazardous fluid into or above
                    an underground source of drinking water.  TRI reporting does not currently
                    distinguish between these two types of wells, although there are important
                    differences in environmental impact between these two methods of injection.

                    TRANSFERS —  are transfers of toxic chemicals in wastes to a facility that
                    is geographically or physically separate from the facility reporting under TRI.
                    Chemicals reported to TRI as transferred are sent to off-site facilities for the
                    purpose of recycling, energy recovery, treatment, or disposal.  The quantities
                    reported represent a movement of the chemical away from the reporting
                    facility. Except for off-site transfers for disposal, the reported quantities do
                    not necessarily represent entry of the chemical into the environment.

                    Transfers to POTWs — are wastewater transferred through pipes or sewers
                    to a publicly owned treatments works (POTW). Treatment or removal of a
                    chemical from the wastewater depends on the nature of the chemical, as well
                    as the treatment methods present at the POTW. Not all TRI chemicals can
                    be treated or removed by a POTW. Some chemicals, such as metals, may be
                    removed but not destroyed and may be disposed of in landfills or discharged
                    to receiving waters.

                    Transfers to  Recycling — are wastes sent off-site  for the purposes of
                    regenerating or recovery by a variety of recycling methods, including solvent
                    recovery, metals recovery, and acid regeneration. Once these chemicals have
                    been recycled, they may  be returned to the originating facility or sold
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Agricultural Chemical Industry
             Chemical Releases and Transfers
                     commercially.
                     Transfers to Energy Recovery ~ are wastes combusted off-site in industrial
                     furnaces for energy recovery. Treatment of a chemical by incineration is not
                     considered to be energy recovery.

                     Transfers to Treatment ~ are wastes moved off-site to be treated through
                     a variety of methods,  including  neutralization,  incineration, biological
                     destruction, or physical separation. In some cases, the chemicals are not
                     destroyed but prepared for further-waste management.

                     Transfers to Disposal -- are wastes taken to another facility for disposal,
                     generally as a release to land or as an injection underground.
IV.A.  EPA Toxic Release Inventory for the Fertilizer, Pesticide, and Agricultural Chemical
Industry

                     This section summarizes the TRI data of fertilizer manufacturing and mixing
                     facilities reporting SIC codes 2873,2874, or 2875 as their primary SIC code
                     and of pesticide  and miscellaneous  agricultural  chemicals formulating
                     facilities reporting SIC code 2879 as their primary SIC code.

                     According to the 1995 Toxics Release Inventory (TRI) data, 190 fertilizer and
                     pesticide facilities reporting SIC 2873,2874, 2875, or 2879 released (to the
                     air, water, or land) and transferred (shipped off-site or discharged to sewers)
                     a total of 106 million pounds of toxic chemicals during calendar year 1996.
                     This represents approximately 2 percent of the 5.6 billion pounds of releases
                     and transfers from all manufacturers (SICs 20-39) reporting to TRI that year.
                     The top two chemicals released by weight are ammonia and phosphoric acid
                     (both from fertilizer manufacturing). These two account for about 89 percent
                     (82 million pounds) of the industry's total releases. Xylene, methanol, and
                     ethylbenzene are the three top chemicals  transferred by weight (all from
                     pesticide formulating).  These three account for about 71 percent (9 million
                     pounds) of the total TRI chemicals transferred  by  the industries.  The
                     variability in facilities' TRI chemical profiles may be attributed to the variety
                     of processes and products in the industries. Eighty-seven percent of the 243
                     different chemicals reported were reported by fewer than 10 facilities.

 Fertilizers (SIC 2873,2874,2875)

                     According to 1996 TRI data, fertilizer manufacturing and mixing facilities
                     released and transferred  approximately 93  million pounds of pollutants
                     during calendar year 1996. One hundred and ninety facilities reported TRI
                     emissions for 46 chemicals. Only 13 of the 46 chemicals (28 percent) were
Sector Notebook Project
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Agricultural Chemical Industry
             Chemical Releases and Transfers
                     reported (as releases and/or transfers) by ten or more facilities, evidence of
                     the diversity  of the industry.  Fertilizer facilities released an average of
                     481,000 pounds per facility and transferred an average of 8,000 pounds per
                     facility. The  high release per facility values are, in a large part, a result of
                     significant releases for ammonia and phosphoric acid from seventy or more
                     facilities.
       Releases
       Transfers
                     Table 14 presents the number and weights of chemicals released by fertilizer
                     manufacturing and mixing facilities reporting SIC 2873, 2874, and 2875 in
                     1996. The total quantity of releases was 91.3 million pounds or 98 percent
                     of the total weight of chemicals reported to TRI by the fertilizer industry (i.e.,
                     releases and transfers).  The top chemical released by this industry is
                     ammonia, accounting for 54 percent of the total releases. Phosphoric acid is
                     the next largest release at 35 percent of the total. Fifty-eight percent of all
                     TRI releases in the fertilizer industry were air emissions, 53 percent as point
                     source and 5 percent as fugitive. Ammonia accounts for 91 percent of air
                     releases. The majority of the other releases were land disposed (32 percent)
                     with phosphoric acid accounting for 99 percent of land disposals.  The
                     remaining nine percent was released as water discharges or underground
                     injections.
                     Table 15 presents the number and weights of chemicals transferred off-site
                     by fertilizer manufacturing and mixing facilities reporting SIC 2873, 2874,
                     or 2875 in 1996. The total amount of transfers was about 1.5 million pounds
                     or only two percent of the total amount of chemicals reported to TRI by the
                     fertilizer industry (i.e., releases and transfers).   Transfers to recycling
                     facilities accounted for the largest amount, 51 percent of the total transfers.
                     The next greatest percentage went for disposal and the rest to treatment
                     facilities. No energy recovery transfers were reported for this industry.
                     Copper compounds, phosphoric acid, and zinc compounds represented the
                     largest transfers (primarily to recycling), as 60 percent of the total transfers.
                     Ammonia only accounted for 4 percent of the transfers compared to 54
                     percent of releases.

Pesticides and Miscellaneous Agricultural Chemicals (SIC 2879)

                     According to 1996 TRI data, pesticide formulating facilities released and
                     transferred approximately 13  million pounds of pollutants during calendar
                     year 1996. One hundred and ninety-three facilities reported TRI emissions
                     for 197 chemicals in 1996.  Only 18  (9 percent) of these chemicals were
                     reported by ten,or more facilities, evidence of the particularly diverse nature
                     of the industry. Pesticide formulating facilities released an average of 10,000
Sector Notebook Project
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Agricultural Chemical Industry
             Chemical Releases and Transfers
                     pounds of pollutants per facility and transferred an average of 59,000 pounds
                     per facility.  The high average transfer per facility is due mostly to high
                     average xylene, ethylbenzene, and methariol transfers.
       Releases
       Transfers
                     Table 16 presents the number and weights of chemicals released by pesticide
                     and miscellaneous agricultural chemicals formulating facilities reporting SIC
                     2879 in 1996..  The total amount of releases was 2.0 million pounds or 15
                     percent of the total quantity of TRI chemicals reported by the pesticide and
                     miscellaneous agricultural chemicals industry (i.e., releases and transfers).
                     This is substantially less than the 98 percent of reported chemicals released
                     by the fertilizer industry. The top two chemicals released by this industry are
                     methanol (23 percent of releases) and dichloromethane (13 percent of
                     releases).

                     About 69 percent (1.4 million pounds) of all the chemicals released by the
                     pesticide industry were released to air in the form of point source emissions
                     (50  percent)  and fugitive air  releases (19 percent).  Air  releases were
                     primarily comprised of dichloromethane, carbon  disulfide, and methyl
                     isobutyl ketone.   Approximately 29 percent  of  the releases were by
                     underground injection, and the remaining releases were to water (2 percent)
                     and land disposal (1 percent).  The relatively large number of chemicals
                     reported to TRI under SIC 2879 compared to the fertilizer industry illustrates
                     the variety of chemical formulations produced by the pesticide industry.
                     Table 17 presents the number and weights of chemical transfers by the
                     pesticide and miscellaneous agricultural chemicals  formulating facilities
                     reporting SIC 2879 in 1996. The total amount of transfers off-site was 11.3
                     million pounds or 85 percent of the total amount of chemicals reported to TRI
                     by the pesticide industry (i.e., releases and transfers). Xylene, methanol, and
                     ethylbenzene accounted for 58, 12, and 10  percent, respectively,  of the
                     chemical TRI transfers.  Transfers to recycling facilities accounted for the
                     largest quantity (51 percent) although only eight facilities reported recycling
                     transfers. Xylene accounted for 84 percent of all recycling transfers. Energy
                     recovery and treatment accounted for 23 and  31 percent respectively.  The
                     remainder of transfers consisted of off-site disposals.
Sector Notebook Project
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September 2000

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      Agricultural Chemical Industry
             Chemical Releases and Transfers
Table 14: 1996 TRI Releases for Agricultural Chemicals Facilities (SICs 2873,2874,2875)
by Number of Facilities Reporting (Releases reported in pounds/year)
Chemical Name
Ammonia
Phosphoric Acid
Zinc Compounds
Manganese Compounds
Nitrate Compounds
Copper Compounds
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Nitric Acid
Chlorine
Methanol
Formaldehyde
Chromium Compounds
Nickel Compounds
Copper
Zinc (Fume or Dust)
Lead Compounds
Hydrogen Fluoride
Diethanolamine
2,4-D
Manganese
Diazinon
Benfluralin
Atrazine
Trifluralin
Chromium
Cadmium Compounds
Cobalt Compounds
Diisocyanates
Certain Glycol Ethers
Carbaryl
N-butyl Alcohol
Quintozene
Mecoprop
Methoxone
Ethylene Glycol
Methyl Isoburyl Ketone
Dicofol
2,4-DP
Asbestos (Friable)
Dicamba
Nickel
Vanadium (Fume or Dust)
Hydrochloric Acid (1995 and after
"Acid Aerosols" Only)
Thiophanate-methyl
Pendimethalin
Oxyfluorfen

# Reporting
Chemical
106
72
56
43
42
37
32

30
30
20
13
11
10
8
8
7
7.'
6
5
5
4
4
3
2
2
1












1
1
1
1
1

1
1
- 1
190**
Fugitive
Air
4,590,371
1,452
3,946
5,292
1,529
1,477
3,237

22,388
5,345
38,447
730
251
255
5
5
17
15,325
5
21
5
0
445
140 '
239
400
\

, 10
0
5
5
0
10
5
750
73,325
250
7
0
12
400

0

0
0
0
4,766,111
Point
Air
43,967,432
8,631
2,969
1,696
261,250
525
1,435,613

17,418
25,787
3,068,775
20,874
0
250
10
8
270
13,820
7,907
251
10
2
258
0
0
0


70
0
5
0
0
250
250
0
16,241
0
250
0
250
0

0

-o
0
0
48,851,072
Water I
Discharges
427,065
2,939,394
7,817
1,500
3,108,211
1,443
5

10
7,818
63,362
10
536
795
0
0
510
15
31,470
0
0
0
0
0
0
0


0
0
0
6
0
0
0
13,000
0

0
0
0
0

0

0
0
0
6.603.991
Jnderground
Injection
539,900
0
65
0
971,850
60
15,000

0
0
20
220
90
270
0
0
0
0
0
0
0
Q
0
0
0
0


0
0
0
" 0
0
0
0
0
0
0
0
0
0
0

260,000

0
0
0
1,787,475
Land
Disposal
78,814
29,071,310
4,023
500
125,960
528
25,587

7,655
0
185
5.
1,430
565
0
0
0
3,309
0
0
0
0
0
. 0
0
0


0
0
0
0
0
0
0
250
0
0
0
0
0
0

0

0
0
0
29,320,121
Total
Releases
49,603,582
32,020,787
18,820
8,988
4,468,800
4,033
1,479,442

47,471
38,950
3,170,789
21,839
2,307
2,135
15
13
797
32,469
39,382
272
15
2
703
140
239
400


80
0
10
5
0
260
255
14,000
89,566
250
257
0
262
400

260,000

0
0
0
91.327,740
Avg.
Releases
Per Facility
467,958
444,733
336
209
106,400
109
46,233

1,582
1,298
158,539
1,680
210
214
2
2
114
4,638
6,564
54
3
1
176
47
120
200


80
0
10
5
0
260
255
14,000
89,566
250
257
0
262
400

260,000

0
0
0
480,672
** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
       Sector Notebook Project
81
September 2000

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      Agricultural Chemical Industry
            Chemical Releases and Transfers
Table 15: 1996 TRI Transfers for Agricultural Chemicals Facilities (SICs 2873,2874,2875)
by Number and Facilities Reporting (Transfers reported in pounds/year)
Chemical Name
Ammonia
Phosphoric Acid
Zinc Compounds :
Manganese Compounds
Nitrate Compounds
Copper Compounds
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Nitric Acid
Chlorine
Methanol
Formaldehyde
Chromium Compounds
Nickel Compounds
Copper
Zinc (Fume or Dust)
Lead Compounds
Hydrogen Fluoride
Diethanolaminc
2,4-D
Manganese
Diazinon
Bcnfluralin
Atrnzinc
Trifluralin
Chromium
Cadmium Compounds
Cobalt Compounds
Diisocyanatcs
Certain Glycol Ethers
Carbaryl
N-butyl Alcohol
Quintozcnc
Mccoprop
Mcthoxonc
Ethylcnc Glycol
Methyl Isobutyl Kctone
Dicofol
2,4-DP
Asbestos (Friable)
Dicamba
Nickel
Vanadium (Fume or Dust)
Hydrochloric Acid (1995 and after "Acid
Aerosols" Only)
Thiophanatc-mcthyl
Pcndimcthalin
Oxyfluorfcn

#
Reporting
Chemical
106
72
56
43
42
37
32

30
30
20
13
11
10
8
8
7
7
6
5
5
4
4
3
2
2

















1

1
1
1
190**
Potw
Transfers
51600
0
5
0
95000
0
0

0
25
1542
250
0
0
0
0
0
0
19940
0
0
0
0
0
0
0


0
0
0
0
0
0
0
0
0
0
0
0
0
0

0

0
0
0
168.362
Disposal
Transfers

289528
1060
1000

11861


250



14207


505
10




















250

19300








337,971
Recycling
Transfers


179327

14657
384419






63230
81600
14657
14657









14657









185





14657






782,046
Treatment
Transfers
11477
418
45834
3834 '
750
11000







20000

5


20000
4613

4608
1250
107880






591

4358
250
250



250

250




4358
4358
4358
250,692
Energy
Recovery Total
Transfers Transfers
63077
289946
226226
4834
110407
407280
0

250
25
1542
250
77437
101600
14657
15167
10
0
39940
4613
0
4608
1250
107880
0
14657


0
0
591
0
4358 -
250
250
185
0
250
250
19300
250
14657

0

4358
4358
4358
0 1.539.071
Avg
Transfer
Per
Facility
595
4,027
4,040
112
2,629
11,008
0

8
1
77
19
7,040
10,160
1,832
1,896
1
0
6,657
923
0
1,152
313
35,960
0
7,329


0
0
591
0
4,358
250
250
185
0
250
250
19,300
250
14,657

0

4,358
4,358
4,358
8.100
** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
       Sector Notebook Project
82
September 2000

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      Agricultural Chemical Industry
            Chemical Releases and Transfers
Table 16:  1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of Facilities
Reporting (Releases reported in pounds/year)
# Reporting
Chemical Name Chemical
1 ,2,4-trimethy Ibenzene
Xylene (Mixed Isomers)
Ethylene Glycol
Naphthalene
Malathion
Diazinon
Ammonia
2,4-D
Carbaryl
Methanol
N-butyl Alcohol
Captan
Quintozene
Trifluralin
Chlorothalonil
2,4-d 2-ethylhexyl Ester
Ethylbenzene
Atrazine
Copper Compounds
Zinc Compounds
Dimethylamine
Arsenic Compounds
Certain Glycol Ethers
Lindane
Bromomethane
Chloropicrin
Cumene
Permethrin
Dicamba
Piperonyl Butoxide
Dimethoate
Mecoprop
Toluene
Thiram
Methyl Parathion
Diuron
Prometryn
Chlorine
Manganese Compounds
Nitrate Compounds
1 , 1 , 1 -trichloroethane
Carbon Disulfide
Methoxone
Metham Sodium
N-methyl-2-pyrrolidone
Carbofaran
Bromoxynil Octanoate
Maneb
Cyanazine
Formaldehyde
Chloromethane
Dichloromethane
O-xylene
Methyl Isobutyl Ketone
Simazine
Hydrochloric Acid (1995 and after
"Acid Aerosols" Only)
Phosphoric Acid
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Metribuzin
Acephate
Chromium Compounds
Chlorodifluoromethane
Maleic Anhydride
M-xylene
Dicofol
Aldicarb
Linuron
Ethyl Dipropylthiocarbamate
Paraquat Dichloride
24
24
22
21
17
17
14
13
12
12
12
12 •
11
11
11
11
10
10
9
9
9
8
8
8
8
8
8
8
7
6
6
6
6
6
6
6
6
6
5
5
5
5
§

5
5
5
5
5
4
4
4
4
4
4
4

4
4

4
4
3
3
3
3
3
3
3
3
1
Fugitive
Air
5310
24494
7856
4536
571
21
20529
1926
1005
12434
1498
519
1050
1304
622
2160
1065
- 4000
547
2299
3547
267
10501
255
9398
2240
108
976
348
35
' 225
510 .
11676
510
716
261
250
6020
6657
5
1729
6817
265
1266
310
22
270
0
285
3020
7434
12585
5602
105310
1005
3698

438
1009

2
255
250
11406
1079
508
210
21
5
6706
son
Point Water Underground
Air Discharges Injection
3185
16327
819
3402
280
227
36889
1535
9005
. 35850
1668
12106
561
2578
1005
1065
421
2430
188
2307
7560
1089
250
255
63421
5835
78
509
324
6
260
920
27350
1000
312
1250
268
2455
75
6
7400
112994
510
258
10
274
251
0
1625
8018
82165
256135
35250
58755
1005
48257

0
1.

1010
1250
88
2441
2385
250
0
1205
5
619
snn
0
0
2521
17
10
10
4908
5
10
8217
0
5
0
87
0
5
• o
5
11
0
0
14
0
5
0
0
0
0
132
0
10
0
39
0
0
8
0
0
0
22000
0
0
250
1
5
1
0
0
0
1083
0
100
5
5
5
0

0
0

5
0
3
0
5
0
0
0
5
2
0
0
17760
2290
0
0
0
2300
0
0
400300
0
5
0
0
0
0
0
1
0
0
250
0
0
0
0
0
0
0
59200
0
0
0
536
0
0
0
0
5 "
0
0
. 0
5
0
0
750
0
0
0
0
0
0
0
0
0
0
0

0
0

0
0
0
0
0
0
0
0
0
29
0
Land
Disposal
0
0
7922
20
0
0
360
255
2500
51
0
0
0
0
1670
. 0
0
0
5
0
0
0
0
250
0
0
0
0
0
0
0
255
71
0
0
0
0
0
0
0
0
0
250
2
5
0
0
0
0
5 '
9
23
5
5
0
56

0
15

0
0
0
0
0
0
0
5
0
0
n
Avg.
Total Releases
Releases Per Facility
8495
58581
21408
7975
861
258
64986
3721
12520
456852
3166
12635
1611
3969
3297
3230
1486
6436
751
4606
11357
1370
10751
765
72819
8075
186
1485
60004
41
495
1685
39672
1510
1028
1519
518
8480
6732
22011
9129
119816
1275
1527
1080
297
521
0
1910
12126
89608
268843
40862
164075
2015
52011

438
1025

1017
1505
341
13847
3469
758
210
1231
15
7356
	 LQflD 	
354
2,441
973
380
51
15
. 4,642
286
1,043
38,071
264
1,053
146
361
300
294
149
644
83
512
1,262
171
1,344
96
9,102
1,009
23
186
8,572
7
83
281
6,612
252
171
253
86
1,413
1,346
4,402
1,826
23,963
255
305
216
59
104
0
382
3,032
22,402
67,211
10,216
41,019
504
13,003

110
256

254
376
114
4,616
1,156
253
70
410
5
2452
™
      Sector Notebook Project
83
September 2000

-------
      Agricultural Chemical Industry
           Chemical Releases and Transfers
Table 16:  1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of Facilities
# Reporting
Chemical Name Chemical
Propachlor
Fluomcturon
Dimcthyltuninc Dicamba
2arboxin
"oppcr
Ethoprop
Tliiophanate-methyl
Pcndimclhalin
ilcxazinonc
Ethylcnebisdithiocarbamic Acid, Salts
and Esters
Trichlorfon
Parathion
Dichlorvos
S,S,s-tributyItrithiophosphate
2,4-db
1,4-dichIorobenzcne
1,2-dichlorocthanc
Chlorobcnzcnc
Phenol
Dicthonolaminc
2,4-dp
Mated
llydrazinc
1,3-dichloropropylcne
Propanil
Amctryn
Cycloatc
Bromoxynil
2,4-d Butoxycthyl Ester
Sodium Dicamba
Dipolassium Endothall
Molinatc
Chlorpyrifos Methyl
Zinc (Fume or Dust)
Nitric Acid
Rcsmcthrin
Dcsmcdipham
Thiophanate Etliyl
Tttiobcncatb
Thiodicarb
Propiconazolc
Cyfluthrin
Femes afen
Quizalofop-cthyl
Lactofcn
Bifcmhrin
Myclobutanil
Antimony Compounds
Chloroplicnols
Cyanide Compounds
Dlisocyanalcs
Lead Compounds
Carbon Tctrachloridc
Formic Acid
Isopropyl Alcohol (Manufacturing,
Strong-acid Process Only, No Supplies)
N.n-dimcthylform amide
Mcthoxychlor
Vinyl Chloride
Tcrt-butyl Alcohol
2-mcthyllactonitrilc
Triphcnyltin Hydroxide
Hcxachlorocyclopentadicne
Dicyclopcntadicnc
Dimethyl Sulfatc
Methyl Ethyl Kctone
Dichloran
P-xylcne
1,3-buIadicnc
nyclnhexnnnl 	 ; 	
3
3
3
3
3
3
3
3
3
2

2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1

1
1
1
1
1
1
1
1
1
1
1
1
1
1
Fugitive
Air
0
260
580
8
0
250
70
970
17
1057



6
1325
470
340
6300
320
533
255
250
0
201
2301
250
255
0
5
262
5
39
, 315
5
250
4000
1
15
530
250
5
3
255
1
847
6

6
250
15

130
66
810
0

1
5
552
20
0
5
141

32

5
77
0
Point Water Underground
Air Discharges Injection
0
512
5
0
5
615
9
260
283
57



6
473
250
1371
57000
0
0
. 255
5
50
12
120
2627
298
49
10
401
750
4
271
. 5
0
398
0
0
281
1000
5
13
250
0
29
1

2
250
41

139
41000
700
15

38
5
644
121
180
5
562

240

5
1200
18
0
0
0
0
0 .
0
0
22
0
0



6
2
0
0
33
0
1
0
0
0
0
0
0
5
1
0
0
0
0
1
0
5
0
0
6
0
0
0
0
6
0

6
0
5

6
0
29
0

0
0
0
0
0
6
0

6

6 •
0
f>
0
0
0
0
0
0
0
0
0
0



6
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
6
0
0
0
• 0
0
0
0

6
73400
0

6
5
0
0

0
0
0
0
0
250
0

6

6
0
o
Land
Disposal
0
0
5
0
0
0
0
140
0
0



6
8
0
0
250
0 ~
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
280
0
0
6
250
0 •
350
0
0
- 0
0

0
0
5

6
0
0
0

0
0
0
0
0
6
0

6

6
0
o
Total
Releases
0
772
590
8
5
865
79
1392
300
1114



0
1808
720
1711
63583
320
534
510
260
50
213
2421
2877
558
52
15
663
755
43
587
10
250
4683
1
15
811
1500.
10
366
505
1
876
7

2
73900
66

269
41071
1539
15

39
10
1196
141
180
260
703

272

10
1277
18
Avg.
Releases
Per Facility
0
257
197
3
2
288
26
464
100
557



6
904
360
856
31,792
160
267
255
130
25
107
1,211
1,439
279
26
8
332
378
22
294
5
125
2,342
1
8
406
750
5
183
253
1
438
4

2
73,900
66

269
41,071
1,539
15

39
10
1,196
141
180
260
703

272

10
1,277
1R
      Sector Notebook Project
84
September 2000

-------
      Agricultural Chemical Industry
            Chemical Releases and Transfers
Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of Facilities
Reporting (Releases reported in pounds/year)
# Reporting
Chemical Name Chemical
SJ-hexane
Pyridine
Propoxur
Di(2-ethylhexyl) Phthalate
Hexachlorobenzene
1 ,2,4-trichlorobenzene
2,4-dichlorophenol
Triethylamine
Hydroquinone
Folpet
Mferphos
Oxydemeton Methyl
Bromacil
Methyl Isothiocyanate
Perchloromethyl Mercaptan
Methyl Isocyanate
Pebulate
Benfluralin
Nitrapyrirf
Triallate
Dodine
Dimethyl Chlorothiophosphate
Temephos
Terbacil
Hydrogen Fluoride
Bromine
Mevinphos
•Phosphine
Creosote
Zineb
Fenbutatin Oxide
Alachlor
Benomyl
Oryzalin
Oxydiazon
Aluminum Phosphide
Bendiocarb
Pronamide
Toluene Diisocyanate (Mixed Isomers)
Propetamphos
Amitraz
Tebuthiuron
Diflubenzuron
Sulprofos
Dinocap
Fenpropathrin
Profenofos
Oxyfluorfen
Triadimefon
Vinclozolin
Fenvalerate
Dimethipin
Triclopyr Triethylammonium Salt
Fenarimol
Acifluorfen, Sodium Salt
Chlorsulfuron
Fluvalinate
Chlorimuron Ethyl
Tribenuron Methyl .

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1 .
1
1
•1
1
1
1
1
1
1








1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
193**
Fugitive
Air
2910
4836

10
5
8000
2630
3298
250
0
200

6
0
0
0
250


250
5
0


6
0
0
0
15


2100


5


5

5

6








i

6

6
0

6
0
369.954
Point Water Underground
Air Discharges Injection
5560
5617

25
0
750
250
101
5
5
0

0
0
510
0
250


250
5
0


0
0
0
1076
25


6


250


250

5

5








6

6

6
1

1
1
995,519
0
0

6
0
0
0
0
0
0
0

6
0
0
0
0


6
0
0


6
0
0
0
0


6


6


6

6

6








6

6

2




39,600
0
0

6
0
750
15390
0
0
0
0

0
0
0
0



6
0
0


6
0
0
0
0


6


6


6

6

6








6

6

6
0

6
0
573.228
Land
Disposal
0
0

6
0
0
0
0
0
0
0

6
0
0
0
0


6
0
0


6
0
0
0 •
0


6


6


6

250

6








6

6

5
0

6
0
15,287
Avg.
Total Releases
Releases Per Facility
8470
10453

35
5
9500
18270
3399
255
5
200

6
0
510
0
500


500
10
0


6
0
0
' 1076
40


2100


255


255

260

5








1

6

7
1

i
i
1.993.588
8,470
10,453

35
5
9,500
18,270
3,399
255
5
200

6
0
510
0
500


500
10
0


6
0
0
1,076
40


2,100


255


255

260

5








1

6

i
i

i
i
10,329
** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
       Sector Notebook Project
85
September 2000

-------
      Agricultural Chemical Industry
            Chemical Releases and Transfers
Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)
 by Number and Facilities Reporting (Transfers reported in pounds/year)
Chemical Name
1,2,4-trimcthylbenzcne
Xylcnc (Mixed Isomers)
Gthylcnc Glycol
Naphthalene
Malnthion
Diazinon
Ammonia
2,4-d
Cartjaryl
Vfethanol
M-butyl Alcohol
Captan
Ouintozenc
Trifluralin
Chlorothaloni!
2,4-d 2-cthylhexyl Ester
Elhylbcnzenc
Atrazinc
Copper Compounds
Zinc Compounds
Dimcthylaminc
Arsenic Compounds
Certain Glycol Ethers
Lindanc
Bromomcthanc
Chloropicrin
Cumcnc
Pcrmcthrin
Dicamba
Piperonyl Butoxidc
Dimcthoatc
Mccoprop
Toluene
Tliiram
Methyl Parathion
Diuron
Promctryn
Chlorine
Manganese Compounds
Nitrate Compounds
1,1,1-trichlorocthanc
Carbon Disulfide
Mcthoxone
Mctliam Sodium
N-mcthyl-2-pyrrolidonc
Carbofuran
Qromoxynil Octanoatc
Maneb
Cyanazinc
Formaldehyde
Chloromcthanc
Oichloromctlianc
0-xylcne
Methyl Isobutyl Kctone
Simazinc
Hydrochloric Acid (1995 and after "Acid
Aerosols" Only)
Phosphoric Aeid
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Mctribuzin
Accphatc
Chromium Compounds
Chlorodifluoro me thane
Malcic Anhydride
M-xylcnc
Dicofol
Aldicarb
Linuron
F-llivl ninmpvllhincnrhamntfi
#
Reporting
Chemical
24
24
22
21
17
17
14
13
12
12
12
12
11
11
11
11
10
10
9
9
9
8
8
8
8
8
8
8
7
6
6
6
6
6
6
6
6
6
5
5
5
5
5
5
5
5
5
5
5-
4
4
4
4
4
4
4

4
4

4
4
3
3
3
3
3
3
3
T
Potw
Transfers
5
9
463
0
0
0
25397
263
5
4367
5
0
4
5
255
5
0
73
0
5
5
10
57107
0
0
0
0
0
5
0
0
5
0
2
0
250
12
6319
5
5
0
0
5
1
0
0
0
0
62
0
0
0
0
940
5
0

0
0

0
250
1
0
0
0
0
0
0
s
Disposal
Transfers
475
2599
3600
823



6017
2750
5
584
2191

2278
2005
2077
231
5673
9267
260

100655

276"


5
1250.



3896

533
360

250

5
5


4778
15862
1770

16605
250
755
1200
26



1255


25549




11257






SQO
Recycling Treatment
Transfers Transfers
43314
4851510 731777
16070 11478
6962
1207
3370
47248
8700
61666
,126038
4150
2081
392714
9772
1518
23721
807182 150224
28161
754 1500
2730
520
231855
1132
1388


'. 1453
1617
125
2082
3091
2497
2171
38081
2120
. 380
6580

21 6309

'. 22147

'. 941
4603
8041
17525
1448
1108
13905
29000

19277 3555
1310
1630
250





13213
15800
155


'. 410
. • 250
32289

Qfilfi
Energy
Recovery
Transfers

1020414

45





1186991


221410



214836


























557


























Total
Transfers
43794
6606309
31611
7830
1207
3370
72645
14980
64421
1317401
4739
4272
614128
12055
3778
25803
1172473
33907
11521
2995
525
332520
58239
1664
0
0
1458
2867
130
2082
3091
6398
2171
38616
2480
630
6842
6319
6340
10
22147
0
5724
21023
9811
17525
18053
1358
14722
30200
26
22832
1310
2570
1510
0

25549
0

13213
16050
11413
0
0
410
250
32289
0
1 0701
Avg
Transfer
Per
Facility
1,825
275,263
1,437
373
71
198
5,189
1,152
5,368
109,783
395
356
55,830
1,096
, 343
2,346
1 17,247
3,391
1,280
333
, 58
41,565
7,280
208
0
0
182
358
19
347
515
1,066
362
6,436
413
105
1,140
1,053
1,268
2
4,429
0
1,145
4,205
1,962
3,505
3,611
272
2,944
7,550
7
5,708
328
643
378
0

6,387
.0

3,303
4,013
3,804
0
0
137
83
10,763
0
3407
      Sector Notebook Project
86
September 2000

-------
      Agricultural Chemical Industry
           Chemical Releases and Transfers
Table 17:  1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)
#
Chemical Name Reporting Potw
Chemical Transfers
'araquat Dichloride
'ropachlor
'luometuron
)imethylamine Dicamba
Carboxin
Copper
ithoprop
'hiophanate-methyl
'endimethalin
[exazinone
ithylenebisdithiocarbamic Acid, Salts and
Esters
'richlorfon
'arathion
Dichlorvos
S,s,s-tributyltrithiophosphate
2,4-db
,4-dichlorobenzene
,2-dichloroethane
Morobenzene
"henol
Diethanolamine
24-dp
i*j-r «p
Naled
lydrazine
,3-dichloropropylene
'ropanil
Ametryn
^ycloate
Sromoxynil
2,4-d Butoxyethyl Ester
Sodium Dicamba
Dipotassium Endothall
vlolinate
Uhlorpyrifos Methyl
Zinc fFume or Dust)
Citric Acid
lesmethrin
Jesmedipham
Thiophanate Ethyl
fhiobencarb
fhiodicarb
"ropiconazole
Dyfluthrin
?omesafen
Juizalofop-ethyl
^actofen
Bifenthrin
Myclobutanil
Antimony Compounds
Chlorophenols
Cyanide Compounds
Diisocyanates
^ead Compounds
Carbon Tetrachloride
formic Acid .
Isopropyl Alcohol (Manufacturing,
Strong-acid Process Only, No Supplies)
i-J.n-dimethylformamide
Methoxychlor
Vinyl Chloride
Tert-buryl Alcohol
2-methyllactonitrile
Triphenyltin Hydroxide
Hexachlorocyclopentadiene
Dicyclopentadiene
Dimethyl Sulfate
Methyl Ethyl Ketone
Dichloran
P-yylene 	
3
3
3
3
3
3
3
3
3
3
2

2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1

1
1
1
1
1
1
1
1
1
1
1
1
32
15
235
0
2
0
0
0
0
250
0

0

6
0
0
0
0
0
0
5
0
5
0
0
0
0
0
0
0
750
0
. 0
0
0
0
0
0
6
5
0
0
0
0
0
0

6
0
0
6
0
0
0

250
6
0
0
6
0
0
0

o
Energy
Disposal Recycling Treatment Recovery Total
Transfers Transfers Transfers Transfers Transfers
5
1505
255
384
250
1167

250











51
39


28
1388
4405





4930
250
1332
2501
250


132
2290



830


54765









250
6490
13785
''. 390
'. 1105


'. 250
12830



'. 145
116
792
1365

'. 1700

! 5
3
3176
'. 51325
1744
9700
1006
8
3256
'. 250
1256
500


'. 600
492

'. 18411
'. 1019
5
3069
48

'. 1198
4
65000

'. 2800


4055
500

416

! 3735


814

7sri
287
6505
15525
255
776
0
1355
1167
0
750
12830

0

104 249
116
792
1365
0
1700
0
61
42
3181
0
51325
1744
9700
1034
1396
3256
750
250
21 5682
500
0
0
600
492
'. 4930
18666
1332
1019
2506
0
3319
48

132
670 4158
4
'. 65000
0
3630
529" 529

2331 61401
500
0
416
0
800 4535
0
0
814

7.50
Avg
Transfer
Per
Facility
96
2,168
5,175
85
259
0
452
389
0
250
6,415

0

125
58
396
683
G
850
0
31
21
1,591
0
25,663
872
4,850
517
698
1,628
375
125
2,841
250
C
(
300
246
2,465
9,333
666
510
1,253
0
1,660
24

132
4,155
*
65,000
l
3,630
529

61,401
50<
1
416
'
4,535


814

. 2«i
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       Agricultural Chemical Industry
             Chemical Releases and Transfers
Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)
 by Number and Facilities Reporting (Transfers reported in pounds/year)
#
Chemical Name Reporting Potw Disposa
Chemical . Transfers Transfers
1,3-butadiene 1 0
Cyclohcxanol 0
N-hcxane 0
Pyridine 8506
Propoxur
Di(2-cthylhcxyl) Phthalate 2
HcNachlorobcnzcnc 0
1,2,4-lrichlorobenzcne 0
2,4-dichlorophcnol 0
TrieUiylaminc 1 0
Hydraquinonc 1 250
Folpet 1 0
Merphos 1 0
Oxydcmcton Methyl 1
Bromacil 1 0
Methyl Isothiocyanate 1 0
Pcrchloromcthyl Mcrcaptan 1 0
Methyl Isooyanatc 1 0
Pcbulate 1 0 500
Bcnfluralin 1
Nitrapyrin 1
Ttiallatc 1 0 509
Dodinc 1 0
Dimethyl Chlorothiophosphate 1 0
Tcmcphos 1
Tcibacil 1
Hydrogen Fluoride 1 , 0
Bromine 1 750
Mcvinplios 1 0
Phosphinc 1 0
Creosote 1 5
Zincb 1
Fenbutatin Oxide 1
Alachlor 1 0
Bcnomyl 1
Oryzalin 1
Oxydinzon 1 0
Aluminum Phosphide 1
Dcndiocarb 1
Pronamidc 1 0
Toluene Diisocyanatc (Mixed Isomers) 1
Propetamphos 1 0 1000
Amitrnz 1 .
Tcbuthiuron 1 0
Diflubcnzuron 1
Sulprofos 0
Dinocap
Fcnpropalhrin
Prolenofos
Qxyfluorfen
Triadimcfon 0
Vinclozolin
Fcnvalerate 0
Dimcthipin
Triclopyr Triethylammonium Salt 0
Fcnarimol
Acifluorfcn, Sodium Salt 0
Chlorsulfuron 1 0
Fluvalinatc 1
Chlorimuron Ethyl 1 0
Tribcnuron Methyl • 1 • 0
193** 106.917 306.983
Recycling
Transfers





























































5,762.544
Energj
; Treatment Recover}
Transfers Transfer

35289
20740 5f


1033
3849 221f
7920 89C

61668 256J




868



250


676
500







602


8600


250


500



937








3994

82


"980:7

36604
17387
2.494.611 2,654.437
Avg
i. Transfer
t Total Per
> Transfers Facility
0 0
35289 35,289
20796 20,796
8506 8,506

1035 1,035
6064 6,064
8810 8,810
0 0
64236 64,236
250 250
0 0
0 0

868 868
0 0
0 0
0 0
750 - 750


1185 1,185
500 500
0 0


6 6
750 750
0 0
0 0
607 607


8600 8,600


250 250


500 500

1000 1,000

937 937

6 6




6 6

3994 3,994

82 82

6 6
9807 9,807

36604 36,604
17387 17,387
11,325,492 58.681
** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
       Sector Notebook Project
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Agricultural Chemical Industry
            Chemical Releases and Transfers
                Top 10 TRI Releasing Agricultural Chemical Companies

                    The TRI database contains a detailed compilation of self-reported, facility-
                    specific chemical releases. The top reporting facilities for the agricultural
                    chemical industries are listed below in Tables 18.; 19, 20, and 21.  Facilities
                    that have reported the primary SIC codes covered under this notebook appear
                    on Table 18 for fertilizers and Table 20 for pesticides and miscellaneous
                    agricultural chemicals.  Tables 19 and 21 contain additional facilities that
                    have reported the SIC codes covered within this report, and one or more SIC
                    codes that are not within the scope of this notebook. Therefore, the second
                    list includes facilities that conduct multiple operations ~ some that are under
                    the scope of this notebook, and some that are not. Currently, the facility-level
                    data do not allow pollutant releases to be broken apart by industrial process.
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Agricultural Chemical Industry
            Chemical Releases and Transfers
Table 18: Top 10 TRI Releasing Fertilizer Manufacturing and Mixing Facilities
(SIC 2873, 2874, 2875)*
Rank
1
2
3
4
5
6
7
8
9
10

Facility
PCS Phosphate Co., Inc. - Aurora, NC
CF Ind. Inc. - Donaldsonville, LA
Unocal Agricultural Products - Kenai, AK
Terra Nitrogen - Catoosa, OK
PCS Nitrogen Fertilizer LP - Millington, TN
IMC Nitrogen Co. - East Dubuque, IL
IMC-Agrico - Uncle Sam, LA
Triad Chemical - Donaldsonville, LA
IMC-Agrico - Mulberry, FL
Farmland Ind. Inc. - Enid, OK
Total
Total TRI Releases in Pounds
13,202,617
5,823,740
4,715,420
4,147,000
3,957,624
3,954,025
3,570,548
3,478,835
3,161,160
2,804,790
45,615,759
Source: US Toxics Release Inventory Database, 1996.
'Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.
Table 19: Top 10 TRI Releasing Facilities Reporting Fertilizer Manufacturing and
Mixing SIC Codes *
Rank
1
2
3
4
5
6
7
8
9
10

Facility
PCS Phosphate Co. Inc. - Geismar, LA
PCS Phosphate Co. Inc. - Aurora, NC
IMC Agrico Co. - St. James, LA
Du Pont - Beaumont, TX
Rubicon Inc. - Geismar, LA
Monsanto Co. - Luling, LA
Coastal Chemical Co. - Cheyenne, WY
PCS Phosphate - White Springs, FL
Vicksburg Chemical Co. - Vicksburg, MS
CF Ind. Inc. - Donaldsonville, LA
SIC Codes Reported in TRI
2873,2874,2819
2874
2873,2874,2819
2822, 2865, 2869, 2873
2865, 2869, 2873
2879, 2834, 2873, 2869, 2819
2813, 2819, 2869, 2873, 2899
2874,2819
2819,2873,2812
2873
Total
Total TRI
Releases in
Pounds
23,192,580
13,202,617
12,794,917
10,880,836
8,327,597
7,742,540
7,674,410
6,961,770
6,139,460
5,823,740
102,740,467
Source: US Toxics Release Inventory Database, 1996.
' Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.
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Agricultural Chemical Industry
           Chemical Releases and Transfers
Table 20: Top 10 TRI Releasing Pesticide and Miscellaneous Agricultural Chemicals
Facilities (SIC 2879)*
Rank
1
2
3
4
5
6
7
8
9
10

Facility
BASF Corp. - Beaumont, TX
Rhone-Poulenc Ag. Co. - Woodbine, GA
American Cyanamid Co. - Palmyra, MO
Zeneca Inc. - Perry, OH
Farmland Ind. Inc. - Saint Joseph, MO
Zeneca Inc. - Pasadena, TX
Bayer Corp. - Kansas City, MO
Trical Inc. - Hollister, CA
FMC Corp. - Institute, WV
McLaughlin Gormley King Co. - Chaska, MN
Total
Total TRI Releases in Pounds
649,472
242,293
227,942
178,291
162,037
149,968
45,881
32,447
22,195
21,611
1,732,137
Source: US Toxics Release Inventory Database, 1996.
* Being included on this list does not mean that the release is associated with non-compliance with environmental
laws
Table 21: Top 10 TRI Releasing Facilities Reporting Pesticide and Miscellaneous
Agricultural Chemicals SIC Codes *
Rank
1
2
3
4
5
6
7
8
9
10

Facilitv
Monsanto Co. - Luling, LA
Monsanto - Alvin, TX
Uniroyal Chemical Co. - Geismar, LA
Du Pont - La Porte, TX
Dow Chemical USA - Midland, MI
Novartis Crop Protection Inc., - St. Gabriel, LA
Tippecanoe Laboratories - Shadeland, IN
Clinton Laboratories - Clinton, IN
Ciba Specialty Chemicals Corp. - Mclntosh,
AL
Du Pont - Belle, WV
SIC Codes Reported in TRI
2879, 2834, 2873, 2869, 2819
2869,2819,2841,2879
2822, 2869, 2879
2819, 2869, 2879
2800, 2819, 2821, 2834, 2869, 2879
2819,2865,2869,2879
2834, 2879
2833, 2879
2879,2821,2865,3069
2821, 2869, 2879
Total
Total TRI
Releases in
Pounds
7,742,540
7,718,029
2,936,127
2,633,242
1,523,414
1,488,589
1,206,435
1,158,105
1,067,347
795,378
28,269,206
Source: US Toxics Release Inventory Database, 1996.
* Being included on this list does not mean that the release is associated with non-compliance with environmental
laws
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 Agricultural Chemical Industry
              Chemical Releases and Transfers
 IV.B. Summary of Selected Chemicals Released
                      The following is a synopsis of current scientific toxicity and fate information
                      for the top chemicals (by weight) that facilities within this sector self-reported
                      as released to the environment based upon 1995 TRI data.  Because this
                      section is based upon self-reported release data, it does not attempt to provide
                      information on management practices employed by the sector to reduce the
                      release of these chemicals. Information regarding pollutant release reduction
                      over time may be available from EPA's TRI and 33/50 programs, or directly
                      from the industrial  trade associations that are listed in Section IX of this
                      document. Since these descriptions are cursory, please consult these sources
                      for a  more detailed description of both the chemicals described  in this
                      section, and the chemicals that appear on the full list of TRI chemicals
                      appearing in Section IV.A.

                      The brief descriptions provided below were taken from the Hazardous
                      Substances Data Bank (HSDB) and the Integrated Risk Information System
                      (IRIS), both accessed via TOXNET.2 The discussions of toxicity describe the
                      range of possible adverse health effects that have been found to be associated
                      with exposure to these chemicals.   These adverse effects may or may not
                      occur  at the levels released to the environment. Individuals interested in a
                      more detailed picture  of the chemical concentrations associated with these
                      adverse effects should consult a toxicologist or the toxicity literature for the
                      chemical to obtain more information. The effects listed below must be taken
                      in context of these exposure assumptions that are explained more fully within
                      the full chemical profiles in HSDB. For more information on TOXNET,
                      contact the TOXNET help line at 1 -800-231 -3 766.
*\
  TOXNET is a computer system run by the National Library of Medicine that includes a number of toxicological
databases managed by EPA, National Cancer Institute, and the National Institute for Occupational Safety and
Health. For more information on TOXNET, contact the TOXNET help line at 800-231-3766. Databases included in
TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART (Developmental and
Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources), EMICBACK
(Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous
Substances  Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical
Substances), and TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on
manufacturing and usage, chemical and physical properties, safety and handling, toxicity and biomedical effects,
pharmacology, environmental fate and exposure potential, exposure standards and regulations, monitoring and
analysis methods, and additional references.
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Agricultural Chemical Industry
             Chemical Releases and Transfers
              Ammonia3 (CAS: 7664-41-7)

                     Sources.  Ammonia is the  primary nitrogen  source  for all nitrogenous
                     fertilizers and ammonium phosphatic fertilizers.

                     Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, and
                     upper respiratory system.

                     Ecologically, ammonia is a  source  of nitrogen (an essential element for
                     aquatic plant growth),  and may therefore contribute to  eutrophication of
                     standing or  slow-moving surface water, particularly  in nitrogen-limited
                     waters  such as the Chesapeake Bay. In  addition,  aqueous  ammonia is
                     moderately toxic to aquatic organisms.

                     Carcinogenicity. There is currently no evidence to suggest that ammonia is
                     carcinogenic.

                     Environmental Fate.    Ammonia  combines with sulfate  ions  in the
                     atmosphere  and is washed  out by  rainfall, resulting in rapid return of
                     ammonia to the soil and surface waters.

                     Ammonia is a central compound in the environmental  cycling of nitrogen.
                     Ammonia in lakes, rivers, and streams is converted to nitrate.

                     Physical Properties. Ammonia is a colorless gas at atmospheric pressure,
                     but is shipped as a liquefied compressed gas. It is soluble to about 34 percent
                     in water and has a boiling point of-28 degrees F. Ammonia is corrosive and
                     has a pungent odor.

              Phosphoric Acid  (CAS: 7664-38-2)

                     Sources.  Phosphoric  acid  is the primary phosphorous source used for
                     phosphatic fertilizers.

                     Toxicity.  Phosphoric acid is toxic by ingestion  and inhalation, and is an
                     irritant to  skin and eyes. The toxicity of phosphoric acid is related to its
                     corrosivity as an acid, with ulceration of membranes and tissues with which
                     it comes in  contact.  Because it is a source of phosphorous, an essential
                     element for aquatic plant growth, phosphoric  acid  may contribute to
                     eutrophication of standing or slow-moving  surface water,  particularly in
                     phosphorous-limited waters such as the Great Lakes.
  The reporting standards for ammonia were changed in 1995. Ammonium sulfate is deleted from the list and
threshold and release determinations for aqueous ammonia are limited to 10 percent of the total ammonia present in
solution. This change will reduce the amount of ammonia reported to TRI. Complete details of the revisions can be
found in 40 CFR Part 372.
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Agricultural Chemical Industry
             Chemical Releases and Transfers
                     Carcinogenicity. There is currently no evidence to suggest that phosphoric
                     acid is carcinogenic.

                     Environmental Fate. The acidity of phosphoric acid may be reduced readily
                     by natural water hardness minerals. The phosphate will persist until used by
                     plants as a nutrient.

                     Physical Properties.  Phosphoric acid is a thick, colorless, and odorless
                     crystalline solid, often used in an aqueous solution. Its boiling point is 415 °
                     F and it is soluble in water.

              Nitrate compounds

                     Sources. Many different nitrate compounds are formed during nitrogenous
                     fertilizer production.

                     Toxicity.  Nitrate compounds that are soluble in water release nitrate ions
                     which can cause both human health and environmental effects.  Human
                     infants exposed to aqueous solutions of nitrate ion can develop a condition
                     in which the blood's ability to carry oxygen is reduced. This reduced supply
                     of oxygen can lead to damaged organs and death.  Because it is a source of
                     nitrogen, an essential  element for aquatic plant growth, nitrate ion  may
                     contribute to eutrophication of standing or  slow-moving surface water,
                     particularly in nitrogen-limited waters, such as the Chesapeake Bay.

                     Carcinogenicity.  There is currently no evidence to suggest that nitrate
                     compounds are carcinogenic.

                     Environmental Fate.   Nitrogen in nitrate is the form of nitrogen most
                     available to plants. In the environment, nitrate ion is taken up by plants and
                     becomes part of the natural nitrogen cycle.  Excess nitrate can stimulate
                     primary production  in plants and can produce changes in the dominant
                     species of plants,  leading  to cultural  eutrophication  and ultimately to
                     deterioration of water quality.

              Methanol (CAS: 67-56-1)

                     Sources. Methanol is generated in ammonia production. It is also used as a
                     solvent and for equipment cleaning in pesticide formulations.

                     Toxicity. Methanol is readily absorbed from the gastrointestinal tract and the
                     respiratory tract and is toxic to humans  in moderate to high doses; In the
                     body, methanol is converted into formaldehyde and formic acid.  Methanol
                     is excreted  as  formic,acid.  Observed  toxic effects at high dose levels
                     generally include central nervous system damage and blindness. Long-term
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Agricultural Chemical Industry
             Chemical Releases and Transfers
                     exposure to high levels of methanol via inhalation cause liver and blood
                     damage in animals.

                     Ecologically, methanol is expected to have low toxicity to aquatic organisms.
                     Concentrations lethal to half the organisms of a test population are expected
                     to exceed one mg methanol per liter water. Methanol is not likely to persist
                     in water or to bioaccumulate in aquatic organisms.

                     Carcinogenicity. There is currently no evidence to suggest that methanol is
                     carcinogenic.

                     Environmental Fate. Methanol is highly volatile and flammable. Liquid
                     methanol is likely to evaporate when left exposed. Methanol reacts in air to
                     produce formaldehyde which contributes to the formation of air pollutants.
                     In the atmosphere it can react with other atmospheric chemicals or be washed
                     out by rain. Methanol is readily degraded by microorganisms in soils and
                     surface waters.

                     Physical Properties.  Methanol is a colorless  liquid with a characteristic
                     pungent odor. It is miscible with water, and its  boiling  point is 147°F.

              Sulfuric Acid (CAS: 7664-93-9)

                     Sources. Sulfuric acid is a raw material of most fertilizer products.

                     Toxicity.  Concentrated sulfuric acid is corrosive.  In  its aerosol  form,
                     sulfuric acid has been implicated in causing and  exacerbating a variety of
                     respiratory ailments.

                     Ecologically,  accidental releases of solution forms of sulfuric acid may
                     adversely affect aquatic life by inducing a transient lowering of the pH (i.e.,
                     increasing the acidity) of surface waters. In addition, sulfuric acid in its
                     aerosol form is also a component of acid rain.  Acid rain can cause serious
                     damage to crops and forests.

                     Carcinogenicity. There is currently no evidence to suggest that sulfuric acid
                     is carcinogenic.

                     Environmental Fate. Releases of sulfuric acid to surface waters and soils
                     will  be neutralized to an extent due to the  buffering capacities  of both
                     systems.  The extent of these reactions will depend on the characteristics of
                     the specific environment.

                     Physical Properties. Sulfuric acid is an oily, odorless liquid  which can be
                     colorless to dark-brown. It is miscible, and its boiling point is 554°F.
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Agricultural Chemical Industry
             Chemical Releases and Transfers
                    Sulfuric acid reacts violently  with water with evolution of heat and is
                    corrosive to metals. Pure sulfuric acid is a solid below 51 °F.

IV.C. Other Data Sources

                    The toxic chemical release data obtained from TRI captures only about 236
                    of the facilities in the Fertilizer, Pesticide, and  Agricultural Chemical
                    Industry.  However, it allows for a comparison across years and  industry
                    sectors.  Reported chemicals are  limited to the approximately 600 TRI
                    chemicals.  A portion of the emissions from agricultural chemical facilities,
                    therefore, are not captured by TRI.  The EPA Office of Air Quality Planning
                    and Standards has compiled air pollutant emission factors for determining the
                    total air emissions of priority pollutants (e.g., total hydrocarbons, SOx, NOx,
                    CO, particulates, etc.) from many chemical manufacturing and formulating
                    sources.

                    The Aerometric Information Retrieval System (AIRS) contains a wide range
                    of information related to stationary sources of air pollution, including the
                    emissions of a number of air pollutants which may be of concern within a
                    particular industry.  With  the exception of volatile organic compounds
                    (VOCs), there is little overlap with the TRI chemicals.reported above. Table
                    22  summarizes annual releases (from the industries for which a Sector
                    Notebook Profile was prepared) of carbon monoxide (CO), nitrogen dioxide
                    (NO2), particulate matter of 10 microns or less (PM10), sulfur dioxide (SO2),
                    and volatile organic compounds (VOCs).
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Agricultural Chemical Industry
            Chemical Releases and Transfers
Table 22: Air Pollutant Releases by Industry Sector (tons/year)
Industry Sector
Metal Mining
Non-Fuel, Non-Metal Mining
Textiles
Lumber and Wood Products
Wood Furniture and Fixtures
Pulp and Paper -
Printing
Inorganic Chemicals
Plastic Resins and Man-made Fibers
Pharmaceuticals
Organic Chemicals
Agricultural Chemicals
Petroleum Refining
Rubber and Plastic
Stone, Clay, Glass and Concrete
Iron and Steel
Metal Castings
Nonferrous Metals
Fabricated Metal Products
Electronics and Computers
Motor Vehicle Assembly
Aerospace
Shipbuilding and Repair
Ground Transportation
Water Transportation
Air Transportation
Fossil Fuel Electric Power
Dry Cleaning
CO
4,951
31,008
8,164
139,175
3,659
584,817
8,847
242,834
15,022
6,389
112,999
12,906
299,546
2,463
92,463
982,410
115,269
311,733
7,135
27,702
19,700
4,261
109
153,631
179
1,244
399,585
145
NO2
49,252
21,660
33,053
45,533
3,267
365,901
3,629
93,763
36,424
17,091
177,094
38,102
334,795
10,977
335,290
158,020
10,435
31,121
11,729
7,223
31,127
5,705
866
594,672
476
960
5,661,468
. 781
PM10
21,732
44,305
1,819
30,818
2,950
37,869
539
6,984
- 2,027
1,623
13,245
4,733
25,271
3,391
58,398
36,973
14,667
12,545
2,811
1,230
3,900
89.0
762
2,338
676
133
221,787
• 10
PT
9,478
16,433
38,505
18,461
3,042
535,712
1,772
150,971
65,875
24,506
129,144
14,426
592,117
24,366
290,017
241,436
4,881
303,599
17,535
8,568
29,766
757
2,862
9,555
712
147
13,477,367
725
S02
1,202
9,183
26,326
95,228
84,036
177,937
88,788
52,973
71,416
31,645
162,488
62,848
292,167
110,739
21,092
67,682
17,301
7,882
108,228
46,444
125,755
3,705
4,345
101,775
3,514
1,815
42,726
7,920
voc
119,761
138,684
7,113
74,028
5,895
107,676
1,291
34,885
7,580
4,733
17,765
8,312
36,421
6,302
198,404
85,608
21,554
23,811
5,043
3,464
6,212
10,804
707
5,542
3,775
144
719,644
40
Source: United States EPA Office of Air and Radiation, AIRS Database. 1 997.
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Agricultural Chemical Industry
             Chemical Releases and Transfers
IV.D.  Comparison of Toxic Release Inventory Between Selected Industries

                     The following information is presented as a comparison of pollutant release
                     and transfer data across industrial categories. It is provided to give a general
                     sense as to the relative scale of TRI releases and transfers within each sector
                     profiled under this project. Please note that the following figure and table do
                     not contain releases and transfers for industrial categories that are not
                     included  in this project, and thus cannot be used to  draw conclusions
                     regarding the total release and transfer amounts that are reported to TRI.
                     Similar information is available within the annual TRI Public Data Release
                     Book.

                     Figure 19 is a graphical representation of a summary of the TRI data for the
                     Fertilizer, Pesticide, and Agricultural Chemical Industry and the other sectors
                     profiled in separate notebooks. The bar graph presents the total TRI releases
                     and total transfers on the vertical axis.  Industry sectors are presented in the
                     order of increasing SIC code. The graph is based on the data shown in Table
                     23 and is meant to facilitate comparisons between the relative amounts of
                     releases and transfers both within and between these sectors.  Table 23 also
                     presents the average releases per facility in each industry. The reader should
                     note that differences in the proportion of facilities captured by TRI exist
                     between industry sectors.  This can be a factor of poor SIC matching and
                     relative differences in the number of facilities reporting to  TRI from the
                     various sectors.  In the case of the Fertilizer, Pesticide, and Agricultural
                     Chemical Industry, the 1995 TRI data presented here covers 236 facilities.
                     These facilities listed SIC 2873,2874,2875, or 2879 as a primary SIC code.
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Agricultural Chemical Industry
             Chemical Releases and Transfers
 Figure 19: Summary of 1995 TRI Releases and Transfers by Industry
finn
500 .
_ 400 .
in
c
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1-
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0














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SIC Range

p Total Releases
g Total Transfers

Source: US EPA 1995 Toxics Release Inventory Database.
SIC Range
22
24
25
2611-2631
2711-2789
2812-2819
2821,
2823, 2824
Industry Sector
Textiles
Lumber and Wood
Products
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemical
Manufacturing
Resins and Plastics
SIC Range
2833, 2834
2861-2869
287
2911
30
32
331
Industry Sector
Pharmaceuticals
Organic Chem. Mfg.
Agricultural Chemicals
Petroleum Refining
Rubber and Misc. Plastics
Stone, Clay, and Concrete
Iron and Steel
SIC
Range
332, 336
333,334
34
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371
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Aericultural Chemical Industry
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Agricultural Chemical Industry
           Pollution Prevention Opportunities
V. POLLUTION PREVENTION OPPORTUNITIES
                     The best way to reduce pollution is to prevent it in the first place.  Some
                     companies have creatively implemented pollution prevention techniques that
                     improve efficiency and increase profits while at the same time minimizing
                     environmental impacts. This can be done in many ways such as reducing
                     material inputs, re-engineering processes to reuse by-products, improving
                     management practices, and substituting toxic chemicals with those less toxic.
                     Some smaller facilities are able to actually get below regulatory thresholds
                     just by reducing pollutant releases through aggressive pollution prevention
                     policies.

                     The Pollution Prevention Act of 1990 established a national policy of
                     managing waste  through source  reduction, which  means preventing the
                     generation of waste.  The Pollution Prevention Act also  established as
                     national policy a hierarchy of waste management options for situations in
                     which source reduction cannot be feasiblely implemented. In the waste
                     management hierarchy, if source reduction is not feasible the next alternative
                     is recycling of wastes, followed by energy recovery, and waste treatment as
                     a last alternative.

                     In order to encourage these approaches, this section provides both general and
                     company-specific descriptions of some pollution prevention advances that
                     have been implemented within the Fertilizer,  Pesticide, and Agricultural
                     Chemical Industry.  While the list is not exhaustive, it does provide core
                     information that can be used as the starting point for facilities interested in
                     beginning their own pollution prevention projects.  This section provides
                     summary information from activities that may be, or are being implemented
                     by this sector. When possible, information is provided that gives the context
                     in which the technique can be used effectively. Please note that the activities
                     described in this section do not necessarily apply to all facilities that fall
                     within this sector. Facility-specific conditions must be carefully considered
                     when pollution prevention options are evaluated, and the full impacts of the
                     change must examine how each option affects air, land and water pollutant
                     releases.

                     The Fertilizer, Pesticide, and Agricultural Chemical Industry uses many
                     pollution prevention  (P2), recycle and  reuse, and water conservation
                     practices.  Wastewaters are primarily generated not by  the production or
                     formulating processes themselves but by cleaning operations of the process
                     areas and associated  equipment.  Because the wastewaters  are mostly
                     cleaning rinsates and not waters of  reaction, the pollution prevention
                     practices are not process-specific.  There are many P2, recycle and reuse, and
                     water conservation practices that are widely accepted and practiced by the
                     Fertilizer, Pesticide, and Agricultural Chemical Industry today.
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           Pollution Prevention Opportunities
                    These pollution prevention, recycle and reuse, and water conservation
                    practices fall into three groups: production practices, housekeeping practices,
                    and practices that use equipment that, by design,  promote  pollution
                    prevention. Some of these practices and equipment conserve water, others
                    reduce the amount of fertilizer or pesticide product in the wastewater, and
                    still others may prevent the generation of a wastewater altogether (USEPA,
                    1996). A number of common P2 practices are listed below.

                    Production practices include:

                           • .  triple-rinsing raw material shipping containers directly into the
                               formulation

                           •   scheduling production to minimize cleanouts

                           •   segregating processing/formulating/packaging equipment by:
                                  - individual product                                    '
                                  - solvent-based versus water-based formulations
                                  - products that contain similar active ingredients in
                                  different concentrations

                           •   storing interior equipment rinse waters for use in formulating the
                               same product

                           •   packaging products directly from formulation vessels

                           •   using raw material drums for packaging final products

                           •   dedicating equipment (possibly only mix tank or agitator) for
                               "hard-to-clean" formulations

                    Housekeeping practices include:

                           •   performing preventive maintenance on all valves, fittings, and
                               pumps

                           •   placing drip pans under leaky valves and fittings or under any
                               valves or fittings where hoses or lines are routinely connected and
                               disconnected

                           •   cleaning up spills or leaks in outdoor bulk containment areas to
                               prevent contamination of storm water
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Agricultural Chemical Industry
          Pollution Prevention Opportunities
                    Equipment that promotes pollution prevention by reducing or eliminating
                    waste water generation includes:

                         , •  low-volume/high-pressure hoses

                          •  spray nozzle attachments for hoses

                          •  squeegees and mops

                          •  low-volume/recirculating floor scrubbing machines

                          •  portable steam cleaners

                          •  drum triple rinsing stations

                          •  roofs over outdoor tank farms (USEPA, 1996)
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Agricultural Chemical Industry
          Pollution Prevention Opportunities
Table 24: Waste Minimization Methods for the Fertilizer, Pesticide, and
Agricultural Chemical Industry
Waste Stream || Waste Minimization Methods
Equipment Cleaning Wastes
Spills and Area Washdowns
Off-Specification Products
Containers
Air Emissions
Miscellaneous Wastewater Streams
Maximize production runs.
Store and reuse cleaning wastes.
Use of wiper blades and squeegees.
Use of low- volume, high-efficiency
cleaning.
Use of plastic or foam "pigs."
Use of dedicated vacuum system.
Use of dry cleaning methods.
Use of recycled water for initial cleanup.
Actively involved supervision.
Strict quality control and automation.
Reformulating off-spec batches.
Return containers to supplier and or reuse
as directed.
Triple rinse containers.
Drums with liners versus plastic drums or
bags.
Segregating solid waste.
Control bulk storage air emissions.
Dedicate dust collection systems.
Use automatic enclosed cut-in hoppers.
Eliminate emissions of ammonia from
reaction of anhydrous ammonia and
phosphoric acid.
Pave high spillage areas.
Source: Guides to Pollution Prevention, The Pesticide Formulating Industry, Center for
Environmental Research Information, United States EPA, Cincinnati, Ohio, 1990.
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Agricultural Chemical Industry
          Pollution Prevention Opportunities
V.A.  Equipment Cleaning
                     Shipping Container/Drum Cleaning Operations

                     Fertilizer and pesticide  facilities  frequently  receive  raw materials in
                     containers such as 55-gallon plastic or steel drums or 30-gallon fiber drams.
                     In some cases, the empty drums are returned to the supplier, but usually the
                     facility is responsible for  disposal of the drums. The simplest, most cost-
                     effective, and best approach to prevent pollution associated with cleaning
                     drams and shipping containers is to rinse empty drums prior to disposal to
                     capture the raw material residue for direct reuse in future formulations of the
                     same product.  In this way, the facility not only eliminates a potential highly
                     contaminated wastewater source, but is also able to recover the product value
                     of the raw material and avoids costs associated with storage of the wastewater
                     (USEPA, 1996). However, pesticide chemicals formulating and packaging
                     facilities and pesticide repackaging and refilling facilities should consult the
                     List of Pollution Prevention Alternative Practices and ensure compliance with
                     the effluent guidelines and standards found in 40 CFR 455 Subparts C and E
                     before implementing pollution prevention techniques listed in this section.

                     Rinsing procedures for pesticide drums are provided in 40 CFR Part 165.
                     The most common method of drum rinsing in the agrichemical industry is
                     triple rinsing. After a drum containing AIs or pesticide products is emptied,
                     it should be triple rinsed with the solvent that will be used in the formulation.
                     This method prevents the creation of a rinsate that cannot be added directly
                     to the formulation (e.g., a facility will not create a water-based rinsate when
                     producing a solvent-based product).  Note in some cases the label may
                     specify how to rinse.

                     Some facilities use a high-pressure, low-volume wash system equipped with
                     a hose and a spray nozzle to triple rinse drums; volumes of five to fifteen
                     gallons of water per drum have been reported.  EPA has identified  many
                     facilities that reuse these rinsates directly in product formulations.  Other
                     facilities treat drum rinsate and reuse the effluent for further drum  or
                     equipment rinsing.  If the rinsate  cannot be reused  directly in  product
                     formulations,  another effective method to reduce  wastewater generation
                     during shipping container/drum cleaning processes is the use of drum rinsing
                     stations (USEPA, 1996).

                     One facility uses a three-cell station for triple-rinsing drums.  The water in
                     the first cell is used for the first rinse, the water in the second cell is used for
                     the second rinse, and the water in the third cell is used for the final rinse. The
                     rinse water in the first cell is reused until it is visually too contaminated to
                     effectively clean the drums. At that time, it is removed from the cell (for
                     treatment) and the rinse water from the second cell is transferred into the first
                     cell.  The rinse water from the third cell is transferred  into the second cell,
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            Pollution Prevention Opportunities
                     and the third cell is refilled with treated effluent from their treatment system.
                     Each cell contains approximately 100 gallons of water; approximately 70
                     drums can be rinsed before the first cell requires water changing (USEPA,
                     1996).

                     Another site uses a unique, closed-loop set-up for emptying and triple rinsing
                     raw material drums.  The system was designed by the facility for several
                     purposes: to aid it in emptying and cleaning drums and performing the triple
                     rinse, to eliminate the need for storage of the water (or solvent) for reuse, and
                     to prevent mathematical errors by the operators during the weighing out of
                     raw materials and  water (or solvent). The system consists of two 55-gallon
                     drums, a formulation tank, and connecting hoses.  One of the drums is
                     permanently fixed on top of the formulation tank. The formulation tank and
                     drum are situated on a load cell (used for weighing).  The second drum,
                     which is full of raw material, is placed on the ground next to the formulation
                     tank.. One hose is used to vacuum out the raw material and transfer it to the
                     drum on the formulations tank/load cell.  The other hose is equipped with a
                     doughnut-shaped nozzle that provides the triple rinse by spraying the interior
                     of the now empty raw material drum. The rinsate that is created by the triple
                     rinse procedure is automatically  removed  by the vacuum line and is
                     transferred to the drum on the formulation tank/load cell.

                     The load cell can be used to weigh the amount of raw material and/or rinsate
                     that is added to the formulation by zeroing out the  weight of the tank and
                     drum.  This allows the volume of both raw material and rinse water (or
                     solvent) to be factored into the total volume of water (or solvent) required in
                     the formulation. The drum on top of the formulation tank is equipped with
                     a spring-loaded valve that enables the operator to take weight measurements
                     prior to emptying the contents of the drum into the mix tank. This set-up has
                     almost completely eliminated operator math errors and related formulation
                     specification problems.

                     Bulk Tank and Equipment Cleaning

                     Pesticide formulating and fertilizer mixing facilities sometimes produce large
                     quantities of formulated pesticide and fertilizer products and receive large
                     quantities of raw materials used to produce those products. Those products
                     and raw materials are stored on site in bulk tanks. The tanks are typically
                     rinsed only when it becomes necessary to use the tank to store a different
                     material. Each time the facility-switches the product stored in a bulk tank, the
                     tank is rinsed.  Bulk tanks are sometimes also rinsed.at the end of a season as
                     a part of general maintenance (USEPA,  1996). Pesticide formulating and
                     fertilizer mixing facilities should consult the List of Pollution Prevention
                     Alternative Practices and ensure compliance with the effluent guidelines and
                     standards found in 40 CFR Part 455 Subparts C and E before implementing
                     pollution prevention techniques involving bulk tank and other equipment
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                    cleaning.

                    Product changeover cleanings  can be eliminated  or  greatly reduced by
                    dedicating equipment to specific products or groups of products.  Although
                    entire lines are not generally dedicated, there are many facilities that dedicate
                    tanks to formulation mixing only, thereby eliminating one of the most highly
                    contaminated wastewater streams generated at pesticide formulating and
                    packaging facilities. Facilities also dedicate lines  to the production of a
                    specific product type, such as water-based versus solvent-based products,
                    thereby reducing the number of cleanings required, and allowing greater reuse
                    of the cleaning water or solvent.

                    Another effective pollution prevention technique is  to schedule production
                    to reduce the number of product changeovers, which reduces the number of
                    equipment interior cleanings required. Facilities may also reduce the number
                    of changeover cleanings required or the quantity of water or solvent used for
                    cleaning by scheduling products in groups. Products may lend themselves to
                    a particular production sequence if they have common active ingredients,
                    assuming the products also have the same solvent base (including water).
                    Where other raw material cross-contamination problems are not a concern,
                    no cleaning would be required between  changeover.  Facilities that have
                    implemented this technique have conducted testing to ensure that product
                    quality is not adversely affected (USEPA, 1996).

                    Scheduling production according to packaging type can reduce changeover
                    cleanings of packaging equipment.  Packaging lines are often able to handle
                    containers of different sizes; a slight adjustment to one packaging line, such
                    as adding a short length of hose, may prevent the use of an entirely different
                    set of packaging equipment that would also require cleaning.  Packaging can
                    also be performed directly out of the formulation vessels to avoid using and
                    subsequently cleaning interim storage tanks and transfer hoses.

                    Another effective pollution prevention and water conservation technique to
                    minimize the quantity of rinse water generated by equipment interior cleaning
                    is the use of water hoses equipped with hand-control devices (for example,
                    spray-gun nozzles  such as those used on garden hoses).  This practice
                    prevents the free flow of water from unattended hoses. Another technique to
                    conserve  water is the use of high-pressure, low-volume washers instead of
                    ordinary hoses.   One of the facilities visited indicated that,  by using high-
                    pressure washers, they reduced typical equipment interior rinse volumes from
                    twenty gallons per rinse to ten gallons per rinse (USEPA, 1996).

                     Steam cleaning can also be a particularly effective method to clean viscous
                    products  that otherwise require considerable volumes of water and/or the
                     addition of a detergent to remove. Many facilities have access to steam from
                     boilers on site; however, if there is  no existing source of steam, steam
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          Pollution Prevention Opportunities
                    cleaning equipment can be purchased.  Although steam generation can
                    increase energy consumption and  add NOX and  SOX pollutants to the
                    atmosphere, there are benefits to be gained. Facilities may end up creating
                    a much smaller volume of wastewater and may potentially avoid the need to
                    use detergents or other cleaning agents that could prevent product recovery.
                    However, steam would be a poor choice for cleaning applications where
                    volatile organic solvents or inerts are part of the product, as the steam would
                    accelerate the volatilization of the organic compounds.

                    Facilities also clean equipment interiors by using squeegees to remove the
                    product from the formulation vessel and by using absorbent "pigs" to clean
                    products out of the transfer lines before equipment rinsing. These techniques
                    minimize the quantity of cleaning water required, although they generate a
                    solid waste stream requiring disposal. Regardless of whether or not residual
                    product is removed from equipment interiors before rinsing,  if certain
                    conditions are  met, equipment interior rinsate can typically be reused as
                    make-up water the next time that a water-based product is being formulated
                    with the same chemical (USEPA, 1996).  Pesticide chemicals formulating
                    and packaging facilities and pesticide repackaging and refilling facilities
                    should consult the List of Pollution Prevention Alternative Practices and
                    ensure compliance with the effluent guidelines and standards found in 40
                    CFR Part 455 Subparts C and E before implementing pollution prevention
                    techniques involving bulk tank and other equipment cleaning.

                    One facility uses a unique method of cleaning to reduce the volume of water
                    needed to clean equipment interiors.  At this facility, the production lines are
                    hooked to dedicated product storage tanks.  Prior to rinsing these production
                    lines, the facility uses air to "blow" the residual product in the line back to
                    product storage. Not only will these lines require less water to clean, but the
                    residual product that is blown back to storage is not diluted and should not
                    affect the product specifications in any way.

                    Another facility drastically reduced dichloromethane usage at several plants
                    by switching to soap and water for cleaning. This change enabled the facility
                    to cut its target chemicals by two-thirds. The facility also reduced the release
                    of carbon tetrachloride, and installed a closed-loop  recycling system,  to
                    reduce water usage (CMA, 1993).

                    Aerosol Container Leak Testing

                    No  method of eliminating wastewater from test baths has been identified.
                    However, the volume of water used may be minimized by using a contained
                    (or  batch) water bath as opposed to a continuous overflow  water bath.  A
                    contained water bath is completely emptied and refilled with water when
                    required, based upon visual inspection by  the operator.   Therefore, the
                    quantity of wastewater generated depends on the frequency  of refilling and
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           Pollution Prevention Opportunities
                    the volume of the bath (200 gallons is a typical volume of the contained water
                    baths). One facility uses a contained water bath and heats the bath with steam
                    to ensure that the temperature of the cans reaches  130°F.  This facility
                    indicated that steam condensation causes some overflow that exits the bath
                    via a standpipe.  A continuous overflow bath would probably generate more
                    wastewater per production unit than a batch water bath (USEPA,  1996).

                    One facility has  installed a diatomaceous earth filter on one DOT test bath.
                    The  facility  recirculates the bath water through  the  filter to  remove
                    contaminants such as oil and grease and suspended solids. The filtered water
                    is then reused in the bath, thereby extending the usefulness of the bath water.
                    The facility anticipates they will dispose of the filter as nonhazardous waste.

                    Another facility uses a  can-washing step prior to  the  DOT  test bath,
                    presenting an additional  source  of  wastewater.   This  can washing  is
                    performed at the operator's discretion to reduce the quantity of contaminants
                    entering the  bath water.   The effectiveness of this step has  not been
                    quantitatively determined (USEPA, 1996).

                    Laboratory Equipment Cleaning

                    Many  pesticide  formulating  and packaging  facilities  operate  on-site
                    laboratories for conducting quality  control tests of raw materials and
                    formulated products.  Wastewater is  generated from these tests  and from
                    cleaning glassware used in the tests. One effective pollution prevention/reuse
                    technique during laboratory equipment cleaning operations is to dedicate
                    laboratory sinks to certain products, and collect any  wastewater  generated
                    from the testing of those products either for reuse in the same product or for
                    transfer back to the AI manufacturer or product registrant. In the cases where
                    the facility uses solvents  in conjunction with the quality  control tests
                    performed in the laboratory, the solvent-contaminated water may not be able
                    to be reused in the process (USEPA, 1996).
V.B. Process Changes
                    Storage Tanks

                    One method to reduce the amount of wastewater from ammonium nitrate
                    production is to incorporate a wastewater evaporator system which reduces
                    the amount of contaminated cooling water discharge. The wastewater passes
                    through a series of evaporation steps whereby the vapors are used as wash
                    water  in the calcium  carbonate filters  and the concentrated solution is
                    pumped to  the neutralizers where  it is mixed with the acidic nitrogen-
                    phosphate solution and used to regulate the nitrogen-phosphate nutrient ratio
                    of the fertilizer. Through this modified technology, steam and electric energy
                    consumption increases somewhat,  but such increases are balanced by the
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           Pollution Prevention Opportunities
                    more effective utilization of nitrogen and the reduction of wastewater. More
                    information on this method can be found in "Waste Water Evaporation
                    Process for Fertilizer Production Technology," Compendium on Low and
                    Non-waste Technology, United Nations Economic and Social Counsel.
                    (http://es.inel.gov/studies/cs244.html)

                    Many methods are available for reducing the amount of emissions resulting
                    from fixed roof storage tanks.   Some of these methods include use of
                    conservation vents, conversion to floating roof tanks, use  of nitrogen
                    blanketing to suppress emissions and reduce material  oxidation, use of
                    refrigerated condensers, use of lean-oil or carbon, absorbers, or use of vapor
                    equilibration lines. When dealing with volatile materials, employment of one
                    or more of these methods can result in cost savings to the facility by reducing
                    raw material losses and  improving compliance  with local  air quality
                    requirements (USEPA, 1996).

                    Air Emission Control Systems

                    Agricultural chemical facilities often produce large quantities of dust which
                    are collected from numerous sources.  The chemical composition of the
                    various dust sources can vary widely.  Opportunities often exist to reduce
                    waste generation through segregation of these waste dusts and particulates.

                    At Daly-Herring Co., in Kingston, NC, dust streams from several different
                    production areas were handled by a single baghouse. Since all of the streams
                    were mixed, none of the waste could be recycled to the process that generated
                    them.  By installing separate dedicated baghouses for each production line,
                    all of the collected pesticide dust could be recycled.- The initial investment
                    for the equipment was $9,600. The payback period was only ten months.
                    Daly-Herring saved over $9,000  per year in disposal costs and $2,000 per
                    year in raw material costs (Hunt,  1989).

                    At FMC Corp. in Fresno, CA, common dust collectors were used by multiple
                    production systems. Due to the cross contamination of materials, recycling
                    was impossible. To promote recycling, the company compartmentalized the
                    dust collectors with each compartment serving a single source. All collected
                    materials are analyzed for cross contamination and if none exists, they are
                    reused in the succeeding product batch. Other work involved the installation
                    of self-contained dust collectors at each inlet hopper dump station so that
                    captured dust can be returned to the system (USEPA, 1996).

                    Facilities may also use wet scrubbers to control air emissions.  Some facilities
                    may only need a wet  scrubber on one particular process (i.e.,  a dedicated
                    scrubber). These facilities have been able to reuse the scrubber blowdown or
                    changed-out scrubber water as make-up water in  the formulation of that
                    particular product. Some facilities with nondedicated scrubbers have been
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Agricultural Chemical Industry
           Pollution Prevention Opportunities
                    able to use the scrubber blowdown or changed-out scrubber water for floor
                    or equipment exterior cleaning (USEPA, 1996).

                    Microprill Formation

                    Microprill formation resulting from partially plugged orifices of melt spray
                    devices can increase fine dust loading and  emissions. Certain  designs
                    (spinning buckets) and practices (vibration of spray plates) help reduce
                    microprill  formation. Reducing the ambient  air temperature  reduces
                    emissions because the air flow required to cool prills and the formation of
                    fumes are decreased at lower temperatures.
V.C.  Good Housekeeping

                    Floor/Wall/Equipment Exterior Cleaning

                    During processing, formulating, and packaging operations, the exteriors of
                    equipment may become soiled  from drips, spills,  and dust (especially
                    equipment located near dry lines). The floors in the area become dirty in the
                    same manner and also  from normal traffic.  Facility workers clean the
                    equipment exteriors and floors for general housekeeping purposes, and to
                    keep sources of product contamination to a minimum. When water is used,
                    these cleaning procedures become a source of wastewater.

                    Wastewater can again be minimized through the use of high-pressure, low-
                    volume washers rather  than ordinary water hoses.   Additionally, some
                    facilities practice steam  cleaning rather than water cleaning of equipment
                    exteriors to reduce the amount of wastewater generated (USEPA, 1996).

                    Instead of hosing down the exterior of a piece of equipment, some facilities
                    wipe equipment exteriors with rags  or use a solvent cleaner, such as a
                    commercially available stainless steel cleaner.  This practice  avoids
                    generating a wastewater stream, but does create a solid waste that, depending
                    on the  solvent used, could be considered a hazardous waste.  Squeegees are
                    also used to clean equipment exteriors and floors, and are not disposed of
                    after single uses. It may be possible to dedicate squeegees to a certain line or
                    piece of equipment, but using squeegees may still require using some water
                    (USEPA, 1996).

                    Some facilities use automated floor scrubbers, which replace the practice of
                    hosing down floors. Floor scrubbers are mechanical devices that continually
                    recirculate cleaning water to clean flat, smooth surfaces with circulating
                    brushes. During operation, the scrubber collects the cleaning water in a small
                    tank that is easily emptied after the cleaning process, or at a later date. Using
                    a floor scrubbing machine can require as  little as five to fifteen gallons of
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                     cleaning solution (typically water) per use.  A mop and a single bucket of
                     water can also be used in place of a hose.  Floor mopping can generate as
                     little as ten gallons of water per cleaning depending on the size of the surface
                     to be cleaned (USEPA, 1996).

                     A number of facilities reuse their floor wash water with and without filtering.
                     One facility has set up its production equipment on a steel-grated platform
                     directly above a collection sump. Following production, the equipment and
                     the floor of the  platform, on which the operator stands when formulating
                     product, are rinsed and the water is allowed to flow into the sump. A pump
                     and a filter have been installed in the  sump area to enable the operator to
                     transfer this rinsate back into the formulation tank for the next formulation.
                     This sump is also connected to floor trenches in the packaging area for the
                     same product. When the exterior of the packaging equipment and the floors
                     in this area are rinsed, this water is directed to the trenches and eventually
                     ends up in the collection sump for reuse (USEPA, 1996).

                     Leaks and Spills Clean-Up

                     Dry products that have leaked or spilled can be vacuumed or swept without
                     generating any wastewater.  Liquid leaks and spills can be collected into a
                     trench or sump (for reuse, discharge, or disposal) with a squeegee, leaving
                     only a residue to be mopped up or hosed down if further water cleanup is
                     required.  Liquid leaks and spills can also be cleaned up using absorbent
                     material, such as absorbent pads or soda ash. For an acidic product, soda ash
                     or a similar base material will also serve to neutralize the spill. If a residue
                     remains, some water may be used for mopping up or hosing the area down,
                     but methods to reduce floor wash should be implemented whenever possible.
                     Many  facilities  clean up leaks and spills from water-based products  with
                     water and then solvent-based products with absorbent materials. Using an
                     absorbent material may be  the best practice for cleaning up small scale
                     solvent-based leaks and spills; however,  EPA does recognize that this
                     material then needs to be disposed of (cross-media transfer). Therefore, good
                     housekeeping practices may be even more important in the case of organic
                     solvent-based product spills and leaks because, if not prevented, these spills
                     and leaks may have to be cleaned up with absorbent material and disposed of
                     (USEPA, 1996).

                     Direct reuse of products which have leaked or  spilled is  another possible
                     pollution prevention technique. If drip pans or other containers are used to
                     catch leaks and spills, the material (either water-based or solvent-based) can
                     be immediately reused in  the product being processed, formulated, or
                     packaged, or stored for use in the next product batch. Collection hoppers or
                     rubs can be installed beneath packaging  fillers to capture spills  and
                     immediately direct the spills back to the fillers.  Leaks or spills around bulk
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                     storage tanks can be contained by dikes, which, in fact, are often required by
                     state regulations (USEPA, 1996).

                     Precipitation Runoff

                     Precipitation runoff includes all precipitation that falls on facility surfaces
                     that are believed to be contaminated. Contaminated precipitation runoff can
                     be prevented by bringing all operations indoors, as many facilities have done,
                     or by covering outdoor storage tanks and dikes with roofs, which has also
                     been done at many facilities. The roofs would ideally extend low enough to
                     prevent crosswinds from blowing rain into spill-containment dikes.  To
                     prevent rainwater contamination, the drain spouts and gutters should conduct
                     roof runoff to areas away from process operations, and the roofs should be
                     kept in good repair (USEPA, 1996).

                     If operations remain outdoors, a transfer,  or containment pad should be
                     installed with a sump or other means of collecting rinse water.  The pad
                     should be constructed of asphalt or concrete and maintained with crack sealer
                     and a top coat sealer to control infiltration.  The pad should also be large
                     enough to contain wind-blown participates from dry materials. If pads are
                     cleaned before a rainfall, then uncontaminated precipitation runoff may be
                     directly discharged to surface drains (CFA, 1996). Facilities can also monitor
                     the water in a containment system by periodically testing  for a variety of
                     contaminants.

                     It may be difficult for facilities that do not require large volumes of water to
                     reuse all  the  precipitation collected in the containment system.  These
                     facilities could keep the containment system free of any spilled pesticides
                     through good housekeeping practices  so that precipitation falling into the
                     containment system does not become contaminated.  Some facilities house
                     their pesticide bulk storage area inside a building or under a covered area to
                     eliminate precipitation from collecting in the containment system, as well as
                     to protect the area from vandalism and severe weather (USEPA, 1996).

                     Containment Pad in the Loading/Unloading Area

                     Agrichemical  dealers sometimes install loading/containment pads in the
                     operation area to contain and collect any product spills that may occur during
                     pesticide loading operations. The pad is usually installed contiguous to the
                     bulk storage tanks and the repackaging of products into smaller containers.
                     Facilities may also conduct all their portable cleaning operations, such as
                     rinsing minibulk containers, directly on the pad in order to contain and collect -
                     the jrinsates.   • -     •                •

                     The pad is normally constructed of concrete and is sloped to a sump area.
                     Some facilities divide the sump area into individual collection basins so that
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                    the facilities can segregate wastewaters contaminated by different products
                    and reuse these wastewaters for applications. For instance, facilities in .the
                    Midwest  frequently have  two  collection basins;  one  basin collects
                    wastewaters contaminated with  corn  herbicides and the other collects
                    wastewaters contaminated with soybean herbicides. As part of this collection
                    system, some facilities install one or more tanks to'store waste water until it
                    can be applied to land, while other facilities use portable minibulk tanks to
                    store the wastewater.  When facilities collect wastewaters that must be
                    segregated by different types of products, multiple storage tanks are used to
                    avoid contamination (USEPA, 1996).

V. D. Energy Efficiency

                    Installation of a Feed-Gas Saturator

                    A mixture of steam and natural gas with a volumetric ratio of steam to carbon
                    of about 3.5:1 is reacted in the primary reformer of reforming ammonia
                    plants. Most of the steam is generated from heat sources within the plant, but
                    the balance of the steam has to be produced in auxiliary boilers.  This retrofit
                    permits the use of low-level heat from the flue gases, which would otherwise
                    be lost, to be used in saturating the feed natural gas with water.  This
                    generates extra steam which replaces some of the steam generated in the
                    boiler (UNEP, 1996).

                    Modification of Convection Coils

                    As a result of other modifications, the temperature profile of the flue gases
                    may change considerably in the  cold-leg section of the primary reformer.
                    This change can be compensated for by replacing the low steam superheat
                    coil with a new one with additional rows of tubes and heavier fins on all
                    tubes (UNEP, 1996).

                    Low-heat Removal of Carbon Dioxide

                    The traditional systems used for removal of carbon dioxide from the process
                    steam uses hot potassium carbonate which requires heat for regeneration.
                    This heat comes from process  heat but needs to be supplemented  with
                    external steam. A new low-heat removal system is now available, which uses
                    flashing for part of the regeneration process, and requires less external heat
                    (UNEP, 1996).

                    Ammonia Synthesis Modifications

                    Ammonia Converter Retrofit
                    The vertical quench-type converters are changed from axial flow to radial
                    flow, greatly decreasing the pressure drop across the converter which in turn
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                    allows the use of smaller size catalyst with a larger surface area.  This
                    improved catalyst yields a higher conversion per pass, generating a lower
                    recycle volume. The lower recycle volume and the lower pressure drop result
                    in reduced energy requirements.   This modification yields an increase
                    effective capacity of the ammonia converter of about 35 percent (UNEP,
                    1996).

                    Addition of Process Computer
                    A dedicated process computer can be installed along with other on-line
                    analysis and control systems to monitor and control key variables. With this
                    system, continuous set point changes are possible to optimize the operation
                    of several plant areas such as hydrogen/nitrogen ratio, steam/carbon ratio,
                    synthesis loop purge, methane leakage, converter control, and refrigeration
                    purge (UNEP, 1996).

                    Hydrogen Recovery from the Purge Gas
                    Inert gases must be pumped from the plant to avoid their buildup in the
                    system. This purge is carried out by removing a side stream of synthesis gas
                    after recovering the ammonia. By installing the proper recovery system, the
                    hydrogen  in  this gas mixture can be  recovered decreasing the energy
                    requirements of the process by about five percent or permitting an increase
                    of about five percent in production capacity (UNEP, 1996).
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VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS

                    This section discusses the federal regulations that may apply to this sector.
                    The purpose of this section is to highlight and briefly describe the applicable
                    federal requirements, and to provide citations for more detailed information.
                    The three following sections are included:

                    •   Section VI.A contains a general overview of major statutes
                    •   Section VLB contains a list of regulations specific to this industry
                    •   Section  VI.C contains a general discussion on State regulation of
                        pesticides
                    •   Section  VI.D contains  a list  of pending  and  proposed regulatory
                        requirements

                    The descriptions within Section  VI are  intended solely  for general
                    information.  Depending upon the nature or scope  of the activities at a
                    particular facility, these summaries may or may not necessarily describe all
                    applicable environmental requirements.  Moreover, they do not constitute
                    formal interpretations or clarifications of the statutes and regulations. For
                    further information, readers should  consult the Code of Federal Regulations
                    (CFR) and other state or local regulatory agencies. EPA Hotline contacts are
                    also provided for each major statute.

VI.A. General Description of Major Statutes

    Federal Insecticide, Fungicide, and Rodenticide Act

                    The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was first
                    passed in 1947, and amended numerous times, most recently by the Food
                    Quality Protection Act  (FQPA)  of 1996. FIFRA provides EPA with the
                    authority to oversee, among other things, the registration, distribution, sale
                    and use of pesticides. The Act applies to all types of pesticides, including
                    insecticides, herbicides,  fungicides, rodenticides, and antimicrobials. FIFRA
                    covers both intrastate and interstate commerce.

                    Establishment Registration
                    Section 7 of FIFRA requires that establishments producing pesticides, or
                    active ingredients used in producing a pesticide subject to FIFRA, register
                    with EPA. Registered establishments must report the types and amounts of
                    pesticides and active ingredients they produce. The Act also provides EPA
                    inspection authority and enforcement authority for facilities/persons that are
                    not in compliance with FIFRA.

                    Product Registration
                    Under section 3 of FIFRA,  all  pesticides (with few exceptions) sold or
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                     distributed in the United  States must be  registered by EPA.  Pesticide
                     registration is very specific and generally allows use of the product only as
                     specified on the label. Each registration specifies the use site, i.e., where the
                     product may be used, and amount that may be applied. The person who seeks
                     to  register the pesticide must file an application for registration.   The
                     application process often requires either  the  citation  or submission  of
                     extensive environmental, health, and safety data.

                     To register a pesticide, the EPA Administrator must make a number  of
                     findings, one of which is that the pesticide, when used in accordance with
                     widespread and commonly recognized practice, will not generally cause
                     unreasonable adverse effects on the environment.

                     FIFRA defines "unreasonable adverse effects on the environment" as "(1) any
                     unreasonable risk to man or  the environment, taking into account the
                     economic, social, and environmental costs and benefits of the use of the
                     pesticide, or (2) a human dietary risk from residues that result from a use of
                     a pesticide in or on any food inconsistent with the standard under section 408
                     of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 346a);"

                     Under FIFRA section 6(a)(2),  after a pesticide  is registered, the registrant
                     must also  notify EPA of any additional facts and  information concerning
                     unreasonable adverse environmental effects of the pesticide. Also, if EPA
                     determines that additional data are needed to support a registered pesticide,
                     registrants may be required to provide additional data. If EPA determines
                     that the registrant(s) did not comply with their request for more information,
                     the registration can be suspended under FIFRA section 3(c)(2)(B) and section
                     4.

                     Use Restrictions
                     As a part of the  pesticide  registration, EPA must  classify the product for
                     general use, restricted use,  or general for some uses and restricted for others
                     (Miller, 1993). For pesticides that may cause unreasonable adverse effects
                     on the environment, including injury to the applicator, EPA may require that
                     the pesticide be applied either by or under the direct supervision of a certified
                     applicator.

                     Reregistration
                     Due to concerns  that  much of  the  safety  data underlying  pesticide
                     registrations becomes outdated and inadequate, in addition to providing that
                     registrations be reviewed every 15 years, FIFRA requires EPA to reregister
                     all pesticides that were registered prior to 1984 (section 4). After reviewing
                     existing data, EPA may approve the reregistration, request additional data to
                     support the registration, cancel, or suspend  the pesticide.
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                    Tolerances and Exemptions
                    A tolerance is the maximum amount of pesticide residue that can be on a raw
                    product and still be considered safe. Before EPA can register a pesticide that
                    is used on raw agricultural products, it must grant a tolerance or exemption
                    from atolerance (40 CFR sections 163.10 through 163.12). Under the Federal
                    Food, Drug, and Cosmetic Act (FFDCA), a raw agricultural product is
                    deemed unsafe if it contains a pesticide residue, unless the residue is within
                    the limits of a tolerance established  by EPA or  is .exempt from  the
                    requirement.

                    Cancellation and Suspension
                    EPA can cancel a registration if it is determined that the pesticide or its
                    labeling does  not comply with the requirements of FIFRA  or causes
                    unreasonable adverse effects on the environment (Haugrud, 1993).

                    In cases where EPA believes that an "imminent hazard" would exist  if a
                    pesticide were to continue to be used through the cancellation proceedings,
                    EPA may suspend the pesticide registration through an order and thereby halt
                    the sale, distribution, and usage of the pesticide.  An "imminent hazard" is
                    defined as an unreasonable adverse effect on the environment or an
                    unreasonable hazard to the survival of a threatened or endangered species that
                    would be the likely result of allowing continued use of a pesticide during a
                    cancellation process.

                    When EPA believes an emergency exists that does not permit a hearing to be
                    held prior to suspending, EPA can issue an emergency order which makes the
                    suspension immediately effective.

                    Imports and Exports
                    Under FIFRA section 17(a), pesticides not registered in the United States and
                    intended solely for export are not required to be registered provided that the
                    exporter obtains and submits to EPA, prior to export, a statement from the
                    foreign purchaser acknowledging that the purchaser is aware that the product
                    is not registered in the United States and cannot be sold for use there. EPA
                    sends these statements to the government of the importing country. FIFRA
                    sets forth additional requirements that must be met by pesticides intended
                    solely for export. The enforcement policy for exports is codified in sections
                    40 CFR sections 168.65, 168.75, and 168.85.

                    Under FIFRA section 17(c), imported pesticides and devices must comply
                    with United States pesticide law. Except where exempted by regulation or
                    statute, imported pesticides must be registered. FIFRA section 17(c) requires
                    that EPA  be notified of the arrival of imported pesticides and devices. This
                    is accomplished through the Notice of Arrival (NOA) (EPA Form 3540-1),
                    which is filled out by the importer prior to importation and submitted to the
                    EPA regional office applicable to the intended port of entry. United States
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                     Customs regulations prohibit  the  importation  of pesticides without a
                     completed NOA.  The EPA-reviewed and signed form is returned to the
                     importer for presentation to United States Customs when the shipment arrives
                     in the United States  NOA forms can be obtained from contacts in the EPA
                     Regional Offices or www.epa.gov/oppfeadl/international/noalist.htm.

                     Additional information on FIFRA and the regulation of pesticides can be
                     obtained from a variety of sources, including EPA's Office  of Pesticide
                     Programs'  homepage   at  -www.epa.gov/pesticides,  EPA's  Office of
                     Compliance,  Agriculture   and   Ecosystem   Division   at
                     http://es.epa.gov/oeca/agecodiv.htm,  or  The   National   Agriculture
                     Compliance   Assistance  Center  toll-free,  at  888-663-2155   or
                     http://es.epa.gov/oeca/ag.  Other sources include the National Pesticide
                     Telecommunications Network toll-free  at 800-858-7378 and the National
                     Antimicrobial Information Network toll-free at 800-447-6349.
       Clean Water Act
                     The primary obj ective of the Federal Water Pollution Control Act, commonly
                     referred to as the Clean Water Act (CWA), is to restore and maintain the
                     chemical, physical, and biological integrity of the nation's surface waters.
                     Pollutants  regulated under the CWA are  classified as either  "toxic"
                     pollutants; "conventional" pollutants, such as biochemical oxygen demand
                     (BOD), total suspended solids (TSS), fecal coliform, oil and grease, and pH;
                     or "non-conventional"  pollutants, including any pollutant not identified as
                     either conventional or priority.

                     The CWA  regulates both direct and  "indirect" dischargers  (those  who
                     discharge to publicly  owned treatment works). The National Pollutant
                     Discharge Elimination  System (NPDES) permitting program (CWA section
                     402) controls direct discharges into navigable waters. Direct discharges or
                     "point source" discharges are  from sources  such as pipes and sewers.
                     NPDES permits, issued by either EPA or an authorized state (EPA has
                     authorized 43 states and 1 territory to administer the NPDES program),
                     contain industry-specific, technology-based and water quality-based limits
                     and establish pollutant monitoring and reporting requirements. A facility that
                     proposes to discharge into the nation's waters must obtain a permit prior to
                     initiating a discharge. A permit applicant must provide quantitative analytical
                     data identifying the types of pollutants present in the facility's effluent. The
                     permit will then set forth the conditions and effluent limitations under which
                     a facility may make a discharge.

                     Water quality-based discharge limits are based on federal or state water
                     quality criteria or standards, that were designed to protect designated uses of
                     surface waters, such as supporting aquatic life or recreation. These standards,
                     unlike the technology-based standards, generally do not take into account
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                     technological feasibility or costs. Water quality criteria and standards vary
                     from state to state, and site to site, depending on the use classification of the
                     receiving body of water. Most states follow EPA guidelines which propose
                     aquatic life and human health criteria for many of the 126 priority pollutants.

                     Storm Water Discharges
                     In 1987 the CWA was amended to require EPA to establish a program to
                     address storm water discharges. In response, EPA promulgated NPDES
                     permitting regulations for storm water discharges. These regulations require
                     that facilities with the following types of storm water discharges, among
                     others, .apply for an NPDES permit: (1) a discharge associated with industrial
                     activity; (2) a discharge  from a large or medium municipal storm sewer
                     system; or (3) a discharge which EPA or the state determines to contribute to
                     a violation of a water quality standard or is a significant contributor of
                     pollutants to waters of the United States.

                     The term "storm water discharge associated with industrial activity" means
                     a storm water discharge  from one of 11 categories of industrial activity
                     defined at 40 CFR section 122.26. Six of the categories are defined by SIC
                     codes while the other five are identified through narrative descriptions of the
                     regulated industrial activity.  If the primary SIC code of the facility is one of
                     those identified in the regulations, the facility is subject to the storm water
                     permit application requirements. If any activity at a facility is covered by one
                     of the five narrative categories, storm water discharges from those areas
                     where  the activities occur are subject to storm  water  discharge permit
                     application requirements.

                     Those facilities/activities that are subject to  storm water  discharge permit
                     application requirements are identified below. To determine  whether a
                     particular facility falls within one of these categories, the regulation should
                     be consulted.

                     Category i:  Facilities subject to storm water effluent guidelines, new source
                     performance standards, or toxic pollutant effluent standards.

                     Category ii:  Facilities  classified as SIC 24-lumber and wood products
                     (except wood kitchen cabinets); SIC 26-paper and allied products (except
                     paperboard containers and products); SIC 28-chemicals and allied products
                     (except drugs  and paints);  SIC 29-petroleum refining;  SIC 311-leather
                     tanning and finishing; SIC 32 (except 323)-stone, clay, glass, and concrete;
                     SIC 33-primary metals; SIC 3441-fabricated  structural metal; and SIC 373-
                     ship and boat building and repairing.

                     Category iii:  Facilities classified as SIC 10-metal mining; SIC  12-coal
                     mining; SIC 13-oil and gas extraction;  and SIC 14-nonmetallic mineral
                     mining.
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                     Category iv: Hazardous waste treatment, storage, or disposal facilities.

                     Category v:  Landfills, land application sites, and open dumps that receive
                     or have received industrial wastes.

                     Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
                     SIC 5093-automotive scrap and waste material recycling facilities.

                     Category vii: Steam electric power generating facilities.

                     Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41 -
                     local passenger transportation; SIC 42-trucking and warehousing (except
                     public warehousing and storage); SIC.43-U.S. Postal Service; SIC 44-water
                     transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
                     storage stations and terminals.

                     Category ix: Sewage treatment works.

                     Category x:  Construction activities except operations that result  in the
                     disturbance of less than five acres of total land area.

                     Category xi:  Facilities classified as SIC 20-food and kindred products; SIC
                     21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
                     products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
                     and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
                     paper and paperboard products; SIC 27-printing, publishing,  and allied
                     industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
                     allied products; SIC 30-rubber and plastics; SIC 31-leather and leather
                     products (except leather and tanning and finishing); SIC 323-glass products;
                     SIC 34-fabricated metal products (exc'ept fabricated structural metal); SIC 35-
                     industrial and commercial machinery and computer equipment; SIC 36-
                     electronic and  other electrical  equipment  and  components;  SIC  37-
                     transportation equipment (except ship and boat building and repairing); SIC
                     38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
                     manufacturing industries; and SIC  4221-422-5-public warehousing  and
                     storage.

                     Pretreatment Program
                     Another type of discharge that is regulated by the CWA is one that goes to a
                     publicly owned treatment works (POTW). The national pretreatment program
                     (CWA section  307(b)) controls the indirect discharge of pollutants to
                     POTWs by "industrial users." Facilities regulated under section 307(b) must
                     meet certain pretreatment  standards.  The goal of the pretreatment program
                     is to protect municipal wastewater treatment plants from damage that may
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                    occur when hazardous, toxic, or other wastes are discharged into a sewer
                    system and to protect the quality of sludge generated by these plants.

                    EPA  has  developed technology-based  standards for industrial users  of
                    POTWs. Different standards apply to existing and new sources within each
                    category.  "Categorical" pretreatment standards applicable to an industry on
                    a nationwide basis are developed by EPA. In addition, another kind of
                    pretreatment standard, "local limits," are developed by the POTW in order to
                    assist the POTW in achieving the effluent limitations in its NPDES permit.

                    Regardless of whether a state is authorized to. implement either the NPDES
                    or the pretreatment program, if it develops its own program, it may enforce
                    requirements more stringent than federal standards.

                    Wetlands
                    Wetlands, commonly called swamps, marshes, fens, bogs, vernal pools,
                    playas, and prairie potholes, are a subset of "waters of the United States," as
                    defined in section 404 of the CWA. The placement of dredge and fill material
                    into wetlands and other water bodies (i.e., waters of the United States) is
                    regulated by the United States Army Corps of Engineers (Corps) under 33
                    CFR  Part 328.  The Corps regulates wetlands by administering the  CWA
                    section 404 permit program for activities that impact wetlands. EPA's
                    authority under section 404 includes veto power of Corps permits, authority
                    to interpret statutory exemptions and jurisdiction, enforcement actions, and
                    delegating the section 404 program to the states.

                    EPA's Office of Water, at (202) 260-5700, will direct callers,with questions
                    about the CWA to the appropriate EPA office.   EPA also maintains a
                    bibliographic database of Office  of Water publications  which can  be
                    accessed through the Ground Water and Drinking Water Resource Center at
                    (202) 260-7786.

                    Oil Pollution Prevention Regulation
                    Section 31 l(b) of the CWA prohibits the discharge of oil, in such quantities
                    as may be harmful, into  the navigable  waters of the United  States  and
                    adjoining shorelines.  The EPA Discharge of Oil regulation, 40 CFR Part
                     110,  provides information regarding these discharges. The Oil Pollution
                    Prevention regulation, 40CFRPartll2, under the authority of section 311 (j)
                    of the CWA, requires regulated facilities to prepare and implement Spill
                    Prevention Control and Countermeasure (SPCC) plans. The intent of a SPCC
                    plan  is to prevent the discharge of oil  from onshore and offshore non-
                    transportation-related facilities.  In 1990, Congress passed the Oil Pollution
                    Act which amended  section 311(j) of the CWA to require facilities that
                    because of their location could reasonably be expected to cause "substantial
                    harm" to  the environment by a discharge of oil to develop  and implement
                    Facility Response Plans (FRP). The intent of a FRP is to provide for planned
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                     responses to discharges of oil.

                     A  facility is  SPCC-regulated  if the facility, due to its location, could
                     reasonably be expected to discharge oil into or upon the navigable waters of
                     the United States or adjoining shorelines, and the facility meets one of the
                     following criteria regarding oil storage: (1) the capacity of any aboveground
                     storage tank exceeds 660 gallons, or (2) the total aboveground storage
                     capacity exceeds 1,320 gallons, or (3) the underground storage capacity
                     exceeds 42,000 gallons. The 40 CFR section 112.7 contains the format and
                     content requirements for a SPCC plan. In New Jersey, SPCC plans can be
                     combined with  DPCC plans required by the state provided there is an
                     appropriate cross-reference index to the requirements of both regulations at
                     the front of the plan.

                     According to the FRP regulation, a facility can cause "substantial harm" if it
                     meets one of the following criteria: (1) the facility has a total oil storage
                     capacity greater than or equal to 42,000 gallons and transfers oil over water
                     to or from vessels; or (2) the facility has a total oil storage capacity greater
                     than  or equal to 1  million gallons and meets any one of the  following
                     conditions: (i) does not have adequate secondary containment, (ii) a discharge
                     could cause "injury" to fish and wildlife and sensitive environments, (iii) shut
                     down a public drinking water intake,  or (iv) has had a reportable oil spill
                     greater than or equal to 10,000 gallons in the past 5 years. Appendix F of 40
                     CFR Part 112 contains the format and content requirements for a FRP. The
                     FRPs that meet  EPA's requirements can be  combined with United States
                     Coast Guard  FRPs or other contingency  plans,  provided  there is  an
                     appropriate  cross-reference index to  the  requirements of all applicable
                     regulations at the front of the plan.

                     For additional information regarding SPCC plans, contact EPA's RCRA,
                     Superfund, and EPCRA Hotline, at (800) 424-9346. Additional documents
                     and  resources  can  be  obtained from  the  hotline's  homepage  at
                     •www.epa.gov/epaoswer/hotline. The hotline  operates weekdays from 9:00
                     a.m. to 6:00 p.m., EST,  excluding federal holidays.
   Safe Drinking Water Act
                    The Safe Drinking  Water Act  (SDWA) mandates that EPA establish
                    regulations to protect human health from contaminants in drinking water.
                    The law authorizes EPA to develop national drinking water standards and to
                    create a joint federal-state system to ensure compliance with these standards.
                    The SDWA also directs EPA to  protect underground sources of drinking
                    water through the control of underground injection of fluid wastes.

                    EPA has developed primary and secondary drinking water standards under
                    its SDWA authority. EPA and authorized states enforce the primary drinking
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                    water standards that are contaminant-specific concentration limits that apply
                    to certain public drinking water supplies. Primary drinking water standards
                    consist  of maximum  contaminant level goals (MCLGs), which are
                    non-enforceable  health-based goals,  and maximum contaminant levels
                    (MCLs), which are enforceable limits set generally as close to MCLGs as
                    possible, considering cost and feasibility of attainment.

                    The SDWA Underground Injection Control (UIC) program (40 CFR Parts
                    144-148) is a permit program which protects underground sources of drinking
                    water by regulating five classes of injection wells. The UIC permits include
                    design, operating, inspection, and monitoring requirements.  Wells used to
                    inject hazardous wastes must also  comply with RCRA corrective action
                    standards in order to be granted a RCRA permit, and must meet applicable
                    RCRA land disposal restrictions standards. The UIC permit program is often
                    state/tribe-enforced, since EPA has  authorized many states/tribes to
                    administer  the program.  Currently, EPA  shares the UIC permit program
                    responsibility in  seven states and runs the program in 10 states and on all
                    tribal lands.
                    The SDWA also provides for a federally-implemented Sole Source Aquifer
                    program, which prohibits federal funds from being expended on projects that
                    may contaminate the sole or principal source of drinking water for a given
                    area, and for a state-implemented Wellhead Protection program, designed to
                    protect drinking water wells and drinking water recharge areas.

                    The SDWA Amendments of 1996 require states to develop and implement
                    source water assessment programs (SWAPs) to analyze existing and potential
                    threats to the quality of the public drinking water throughout the state. Every
                    state is required to submit a program to EPA and to complete all assessments
                    within 3 ¥2 years  of EPA approval of the program.  SWAPs include:  (1)
                    delineating the source water protection area; (2) conducting a contaminant
                    source inventory; (3) determining the susceptibility of the public water supply
                    to contamination from the inventories sources; and (4) releasing the  results
                    of the assessments to the public.

                    EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
                    and distributes guidance pertaining to SDWA standards.   The Hotline
                    operates from 9:00 a.m. through 5:30 p.m., EST, excluding federal holidays.
                    Visit the website at http://www.epa.gov/ogwdwfor additional material.
   Resource Conservation and Recovery Act
                    The Solid  Waste Disposal Act (SWDA), as  amended by the Resource
                    Conservation and Recovery Act (RCRA) of 1976, addresses  solid and
                    hazardous waste management activities. The Act is commonly referred to as
                    RCRA. The Hazardous and Solid Waste Amendments (HSWA) of 1984
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                    strengthened RCRA's waste management provisions and added Subtitle I,
                    which governs underground storage tanks (USTs).

                    Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
                    260-299) establish a "cradle-to-grave" system governing hazardous waste
                    from the point of generation to disposal. RCRA hazardous wastes include the
                    specific materials listed in the regulations (discarded commercial chemical
                    products, designated with the code "P"  or "U"; hazardous wastes from
                    specific industries/sources, designated with  the code  "K"; or hazardous
                    wastes from non-specific sources, designated with the code "F") or materials
                    which exhibit a hazardous waste characteristic (ignitability, corrosivity,
                    reactivity, or toxicity and designated with the code "D").

                    Entities that generate hazardous waste are subject to waste accumulation,
                    manifesting, and recordkeeping standards.  A hazardous waste facility may
                    accumulate hazardous waste for up to 90 days (or 180 days depending on the
                    amount generated per month) without a permit or interim status. Generators
                    may also treat hazardous waste in accumulation tanks or containers (in
                    accordance with the requirements of 40 CFR section 262.3 4) without a permit
                    or interim status.

                    Facilities that treat, store, or dispose  of hazardous waste are  generally
                    required to obtain a RCRA permit. Subtitle C permits for treatment, storage,
                    or disposal facilities contain general facility standards such as contingency
                    •plans, emergency procedures, recordkeeping and reporting requirements,
                    financial assurance mechanisms, and unit-specific standards.  RCRA also
                    contains provisions (40 CFR Part 264 Subparts  I  and S)  for conducting
                    corrective actions which govern the cleanup of releases of hazardous waste
                    or constituents from solid waste management units at RCRA treatment,
                    storage, or disposal facilities.

                    Although RCRA is a federal  statute, many  states  implement the RCRA
                    program.  Currently, EPA has delegated its authority to implement various
                    provisions  of RCRA to 47 of the 50 states and two United States territories.
                    Delegation has not been given to Alaska, Hawaii, or Iowa.

                    Most RCRA requirements are not industry specific but apply to any company
                    that generates, transports, treats, stores, or disposes of hazardous waste. Here
                    are some important RCRA regulatory requirements:

                    Criteria for  Classification of Solid Waste Disposal Facilities and
                    Practices (40 CFR Part 257) establishes the criteria for determining which
                    solid waste disposal facilities and practices pose a reasonable probability of
                    adverse effects on health or the environment. The criteria were adopted to
                    ensure non-municipal, non-hazardous  waste disposal units  that  receive
                    conditionally exempt small quantity generator waste do not present risks to
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                    human health and environment.

                    Criteria for Municipal  Solid  Waste Landfills (40  CFR Part 258)
                    establishes minimum national criteria for all municipal solid waste landfill
                    units, including those that are used to dispose of sewage sludge.

                    Identification  of Solid  and Hazardous  Wastes (40  CFR Part 261)
                    establishes the  standard to determine whether the material in question is
                    considered a solid waste and, if so, whether it is a hazardous waste or is
                    exempted from regulation.

                    Standards for Generators of Hazardous Waste  (40 CFR Part 262)
                    establishes the responsibilities of hazardous waste generators including
                    obtaining an EPA ID number,  preparing a manifest,  ensuring  proper
                    packaging and labeling, meeting standards for waste accumulation units, and
                    recordkeeping and reporting requirements.  Generators can accumulate
                    hazardous waste on-site for up to 90 days  (or 180 days depending on the
                    amount of waste generated) without obtaining a permit.

                    Land Disposal Restrictions (LDRs) (40  CFR Part 268) are regulations
                    prohibiting the disposal of hazardous waste  on land without prior treatment.
                    Under the LDRs program, materials must meet treatment standards prior to
                    placement in a RCRA land disposal unit (landfill, land treatment unit, waste
                    pile, or surface impoundment).  Generators of waste subject to the LDRs
                    must provide notification of such to the designated TSD facility to ensure
                    proper treatment prior to disposal.

                    Used Oil Management Standards (40 CFR Part 279) impose management
                    requirements affecting the storage, transportation, burning, processing, and
                    re-refining of the used oil.   For parties that merely generate used oil,
                    regulations establish storage standards.  For a party considered a used oil
                    processor, re-refiner, burner, or  marketer  (one who  generates and  sells
                    off-specification used oil directly to a used oil burner), additional tracking
                    and paperwork requirements  must be satisfied.

                    Tanks and  Containers Standards (40 CFR Part 264-265, Subpart CC)
                    contains unit-specific standards for all units used to store, treat, or dispose of
                    hazardous waste. Tanks and containers used to store hazardous waste with a
                    high volatile organic concentration must meet emission standards under
                    RCRA.  Regulations require generators to  test the waste to determine the
                    concentration of the waste, to satisfy tank and container emissions standards,
                    and to inspect and monitor regulated units.  These regulations apply to all
                    facilities who  store  such  waste, including large  quantity generators
                    accumulating waste prior to shipment offsite.
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             •      Underground Storage Tanks (USTs) containing petroleum and hazardous
                    substances are regulated under Subtitle I of RCRA. Subtitle I regulations (40
                    CFR Part 280)  contain tank design and release detection requirements, as
                    well as financial responsibility and corrective action standards for USTs. The
                    UST program also includes upgrade requirements for existing tanks that were
                    to be met by December 22, 1998.

             •      Boilers and Industrial Furnaces  (BIFs) that use or burn fuel containing
                    hazardous waste must comply with  design and operating standards. BIF
                    regulations  (40 CFR Part 266, Subpart H) address unit design,  provide
                    performance standards, require emissions monitoring, and, in some cases,
                    restrict the type of waste that may be burned.

                    EPA'sRCRA, Superfund, andEPCRA Hotline, at (800) 424-9346, responds
                    to questions and .distributes guidance regarding all RCRA  regulations.
                    Additional documents and resources can be obtained from the hotline's
                    homepage at http://www.epa.gov/epaoswer/hotline.   The RCRA  Hotline
                    operates weekdays from  9:00  a.m. to 6:00 p.m.,  EST,  excluding federal
                    holidays.     •

   Comprehensive Environmental Response, Compensation, and Liability Act

                    The Comprehensive Environmental Response, Compensation, and Liability
                    Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA
                    to respond to releases, or threatened releases, of hazardous substances that
                    may endanger public health, welfare, or the environment. The CERCLA also
                    enables EPA to force parties responsible for environmental contamination to
                    clean it up or to reimburse the Superfund for response or remediation costs
                    incurred by EPA.  The Superfund Amendments and Reauthorization Act
                    (SARA) of 1986 revised various sections of CERCLA, extended the taxing
                    authority for the Superfund, and created a free-standing law, SARA Title III,
                    also known as the Emergency Planning and Community Right-to-Know Act
                    (EPCRA).

                    The CERCLA hazardous substance release reporting regulations (40 CFR
                    Part 302) direct the person in charge of a facility to report to  the National
                    Response Center (NRC) any environmental release of a hazardous substance
                    which equals,or exceeds  a reportable quantity.  Reportable quantities are
                    listed in 40  CFR section 302.4. A release report may trigger a response by
                    EPA or by one or more federal or state emergency response authorities.

                    EPA implements hazardous  substance responses according to procedures
                    outlined in the National Oil and Hazardous Substances Pollution Contingency
                    Plan (NCP) (40 CFR Part 300). The NCP includes provisions for cleanups.
                    The National Priorities List (NPL) currently includes approximately 1,300
                    sites.  Both EPA .and states can act at other sites; however, EPA provides
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                    responsible parties the opportunity to conduct cleanups and encourages
                    community involvement throughout the Superfund response process.

                    EPA's RCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers
                    questions and references guidance pertaining to the Superfund program.
                    Documents and resources can be obtained from the hotline's homepage at
                    http://www.epa.gov/epaoswer/hotline. The Superfund Hotline operates
                    weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays.

   Emergency Planning and Community Right-To-Know Act

                    The Superfund Amendments and Reauthorization Act (SARA) of 1986
                    created the Emergency  Planning  and  Community  Right-to-Know Act
                    (EPCRA, also  known as SARA Title III), a  statute designed to improve
                    community access to information about chemical hazards and to facilitate the
                    development of chemical emergency response plans by state and local
                    governments.  Under EPCRA, states establish State Emergency Response
                    Commissions  (SERCs), responsible for coordinating certain emergency
                    response activities and for appointing Local Emergency Planning Committees
                    (LEPCs). EPCRA and the EPCRA regulations (40 CFR Parts 350-372)
                    establish four types of reporting obligations  for facilities which store or
                    manage specified chemicals:

                          EPCRA section 302 requires facilities to notify the SERC and LEPC
                          of the presence of any extremely hazardous substance at the facility
                          in an amount in excess of the established threshold planning quantity.
                          The list of extremely hazardous substances  and their threshold
                          planning quantities is found at 40 CFR Part 355, Appendices A and
                          B.

                    •      EPCRA section 303 requires that each LEPC develop an emergency
                          plan. The plan must contain (but is not limited to) the identification
                          of facilities within the planning district, likely routes for transporting
                          extremely hazardous substances, a description of the methods and
                          procedures to be followed by facility owners and operators, and the
                          designation  of  community  and  facility emergency  response
                          coordinators.

                          EPCRA section 304 requires the facility to notify the SERC and the
                          LEPC in the event of a release exceeding the reportable quantity of a
                          CERCLA hazardous substance (defined at 40 CFR Part 302) or an
                          EPCRA extremely hazardous substance.

                    •      EPCRA sections 311 and 312 require a facility at which a hazardous
                         - chemical, as defined by the Occupational Safety and Health Act, is
                          present in an amount exceeding a specified threshold to submit to the
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                           SERC, LEPC and local fire department material safety data sheets
                           (MSDSs) or lists of MSDSs and hazardous chemical inventory forms
                           (also known as Tier I and II forms). This information helps the local
                           government respond in the event of a spill or release of the chemical.

                           EPCRA section 313 requires certain covered facilities, including SIC
                           codes 20 through 39 and others, which have ten or more employees,
                           and which manufacture, process, or use specified chemicals  in
                           amounts greater than threshold quantities, to submit an annual toxic
                           chemical release report. This report, commonly known as the Form
                           R, covers releases and transfers of toxic chemicals to various facilities
                           and environmental media.  EPA maintains the data reported in a
                           publically accessible database known as the Toxics Release Inventory
                           (TRI).

                    All information submitted  pursuant to EPCRA regulations is publicly
                    accessible, unless protected by a trade secret claim.

                    EPA'sRCRA,  Superfund, and EPCRA Hotline, at (800) 535-0202, answers
                    questions and distributes guidance regarding the emergency planning and
                    community right-to-know regulations.  Documents and resources can  be
                    obtained   from   the .  hotline's   homepage   at
                    http://www.epa.gov/epaoswer/hotline.    The  EPCRA Hotline  operates
                    weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal  holidays.
    Clean Air Act
                    The Clean Air Act (CAA) and its amendments are designed to "protect and
                    enhance the nation's air resources so as to promote the public health and
                    welfare and the productive capacity of the population." The CAA consists
                    of six sections, known as Titles, which direct EPA to establish national
                    standards for ambient air quality and for EPA and the states to implement,
                    maintain, and enforce these  standards  through a variety of mechanisms.
                    Under the CAA, many facilities are required to obtain operating permits that
                    consolidate their air emission requirements.  State and local governments
                    oversee, manage, and enforce many of the requirements of the CAA. CAA
                    regulations appear at 40 CFR Parts 50-99.

                    Pursuant to Title I of the CAA, EPA has established national ambient air
                    quality standards (NAAQSs) to limit levels of "criteriapollutants," including
                    carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur
                    dioxide.  Geographic areas that meet NAAQSs for a given pollutant are
                    designated as attainment areas;  those that do  not  meet NAAQSs are
                    designated as non-attainment areas. Under section 110 and other provisions
                    of the CAA, each state must develop a  State Implementation Plan (SIP) to
                    identify sources of air pollution and to determine what reductions are required
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                    to meet federal air quality standards. Revised NAAQSs for particulates and
                    ozone were finalized in 1997. However, these revised NAAQSs are currently
                    being challenged before the U.S. Supreme Court.

                    Title I also authorizes EPA to establish New Source Performance Standards
                    (NSPS), which  are nationally uniform emission standards for new and
                    modified stationary sources falling within particular industrial categories.
                    The NSPSs are based  on the pollution control technology available to that
                    category of industrial source (see 40 CFR Part 60).

                    Under Title I, EPA establishes and enforces National Emission Standards for
                    Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
                    toward controlling specific hazardous air pollutants (HAPs). Section 112(c)
                    of the CAA further directs EPA to develop a list of sources that emit any of
                    188 HAPs andto develop regulations for these categories of sources. To date
                    EPA has listed  185 source categories and developed a schedule for the
                    establishment of emission  standards.  The emission standards are  being
                    developed for both new and existing sources based on "maximum achievable
                    control  technology"  (MACT).  The  MACT is defined as the control
                    technology achieving the maximum degree of reduction in the emission of the
                    HAPs, taking into account cost and other factors.

                    Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
                    and planes.  Reformulated gasoline, automobile pollution control devices,
                    and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
                    uses to regulate mobile air emission sources.

                    Title IV-A establishes a sulfur  dioxide  and nitrogen  oxides  emissions
                    program designed to reduce the formation of acid rain. Reduction of sulfur
                    dioxide releases  will  be obtained by granting  to certain  sources limited
                    emissions allowances  that are set below previous levels of sulfur dioxide
                    releases.

                    Title V of the CAA establishes an operating permit program for  all "major
                    sources" (and certain other sources) regulated under the CAA. One purpose
                    of the operating permit is to include in a single document all air emissions
                    requirements that apply to a given facility.  States have developed the permit
                    programs in accordance with guidance and regulations from EPA. Once a
                    state program is approved by EPA, permits are issued and monitored by that
                    state.

                    Title VI of the CAA is intended to protect stratospheric ozone by phasing out
                    the manufacture  of ozone-depleting chemicals and restrict their usage and
                    distribution.  Production of Class  I substances, including 15  kinds of
                    chlorofluorocarbons (CFCs), were phased out (except for essential uses) in
                    1996.  Methyl bromide, a common pesticide, has  been identified as  a
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                    significant stratospheric ozone depleting chemical.  The production and
                    importation of methyl bromide, therefore, is currently being phased out in the
                    United States and internationally. As specified in the Federal Register of June
                    1,1999 (Volume 64, Number 104) and in 40 CFR Part 82, methyl bromide
                    production and importation will be reduced from 1991 levels by 25% in
                    1999, by 50% in 2001, by 70% in 2003, and completely phased out by 2005.
                    Some uses of methyl bromide, such the  production,  importation, and
                    consumption of methyl bromide to fumigate commodities entering or leaving
                    the United States or any state (or political subdivision thereof) for purposes
                    of compliance with Animal and Plant Health Inspection Service requirements
                    or with any international, federal, state, or local sanitation or food protection
                    standard, will be exempt from this rule. After 2005, exceptions may also be
                    ma'de for critical agricultural uses.  The United States EPA and the United
                    Nations Environment Programme have identified alternatives to using methyl
                    bromide in agriculture.  Information on the methyl bromide phase-out,
                    including alternatives, can be found at the EPA Methyl Bromide Phase-Out
                    Web Site: (http://www.epa.gov/docs/ozone/mbr/mbrqa.html).

                    EPA's Clean Air Technology Center, at (919) 541-0800 and at the Center's
                    homepage at http://www.epa.gov/ttn/catc, provides general assistance and
                    information  on CAA standards.  The Stratospheric Ozone Information
                    Hotline, at (800)  296-1996  and at http://www.epa.gov/ozone, provides
                    general information about regulations promulgated under Title VI of the
                    CAA;  EPA's  EPCRA  Hotline,  at   (800)  535-0202  and  at
                    http://www.epa.gov/epaoswer/hotline, answers questions about accidental
                    release prevention under CAA section 112(r); and information on air toxics
                    can  be   accessed  through  the   Unified  Air   Toxics  website  at
                    http://www.epa.gov/ttn/uatw. In addition, the Clean Air Technology Center's
                    website includes recent CAA rules, EPA guidance documents, and updates
                    of EPA activities.

    Toxic Substances Control Act

                    The Toxic Substances Control Act (TSCA) granted EPA authority to create
                    a regulatory framework to collect data on chemicals in order to evaluate,
                    assess, mitigate, and control risks which may be posed by their manufacture,
                    processing, and use. TSCA provides a variety of control methods to prevent
                    chemicals from posing unreasonable risk.   It is important to note that
                    pesticides as defined in FIFRA are not included  in the definition of  a
                    "chemical substance" when manufactured, processed, or  distributed in
                    commerce for use as a pesticide.

                    TSCA standards may apply at any point during a chemical's life cycle. Under
                    TSCA section 5, EPA established an inventory of chemical substances. If a
                    chemical substance is not already on the inventory, and has not been excluded
                    by TSCA, a premanufacture notice (PMN) must be submitted to EPA prior
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                    to manufacture or import. The PMN must identify the chemical and provide
                    available information on health and environmental effects. If available data
                    are not sufficient to evaluate the chemical's  effects, EPA  can impose
                    restrictions pending the development of information on its health and
                    environmental effects.   EPA can also restrict significant new uses  of
                    chemicals based upon factors such as the projected volume and use of the
                    chemical.

                    Under TSCA section 6, EPA can ban the manufacture or distribution  in
                    commerce, limit the use, require labeling, or place other restrictions on
                    chemicals that pose unreasonable risks. Among the chemicals EPA regulates
                    under section 6 authority are asbestos, chlorofluorocarbons (CFCs), lead, and
                    polychlorinated biphenyls (PCBs).

                    Under TSCA section 8(e), EPA requires the producers and importers (and
                    others) of chemicals to report information on a chemical's production, use,
                    exposure, and risks.  Companies producing and importing chemicals can be
                    required to report unpublished health and safety  studies on listed chemicals
                    and  to collect  and  record any allegations of adverse reactions or any
                    information indicating that a substance may pose  a substantial risk to humans
                    or the environment.

                    EPA's TSCA Assistance Information Service, at 202 554-1404, answers
                    questions and distributes guidance pertaining to Toxic Substances Control
                    Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST,
                    excluding federal holidays.

    Coastal Zone Management Act

                    The  Coastal Zone Management Act (CZMA)  encourages states/tribes  to
                    preserve, protect, develop, and where possible, restore or enhance valuable
                    natural coastal resources such as wetlands, floodplains, estuaries, beaches,
                    dunes, barrier islands, and coral reefs, as well as the fish and wildlife using
                    those habitats.  It includes areas bordering the Atlantic, Pacific, and Arctic
                    Oceans, Gulf of Mexico, Long Island Sound, and Great Lakes. A unique
                    feature of this law is that participation by states/tribes is voluntary.

                    In the Coastal Zone  Management Act  Reauthorization Amendments
                    (CZARA) of 1990, Congress identified nonpoint source pollution as a major
                    factor in  the continuing degradation of coastal waters.  Congress also
                    recognized that effective solutions to nonpoint source pollution could be
                    implemented at the state/tribe and local levels. In CZARA, Congress added
                    section 6217 (16 U.S.C. section  1455b), which calls upon states/tribes with
                    federally-approved coastal zone management  programs to develop and
                    implement coastal nonpoint pollution control programs. The section 6217
                    program is administered at the federal level jointly by EPA and the National
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                    Oceanic and Atmospheric Agency (NOAA).

                    Section 6217r(g) called for EPA, in consultation with other agencies, to
                    develop guidance on "management measures" for sources of nonpoint source
                    pollution in coastal waters. Under section 6217, EPA is responsible for
                    developing technical  guidance to assist states/tribes in designing coastal
                    nonpoint pollution control programs.  On January 19, 1993, EPA issued its
                    Guidance Specifying Management Measures For  Sources  of Nonpoint
                    Pollution in Coastal Waters, which addresses five major source categories of
                    nonpoint pollution: (1) urban runoff, (2) agriculture runoff, (3)  forestry
                    runoff, (4) marinas and recreational boating, and (5) hydromodification.

                    Additional information on coastal zone management may be obtained from
                    EPA's   Office  of  Wetlands,   Oceans,   and  Watersheds   at
                    http://www.epa.gov/owow or from the Watershed Information Network at
                    http://www.epa.gov/win.,  The   NOAA    website    at
                    http://www. nos. noaa. gov/ocrm/czm/also contains additional information on
                    coastal zone management.
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VLB. Industry Specific Requirements

                    The agricultural chemical industry is affected by several major federal
                    environmental statutes. In addition, the industry is subject to numerous laws
                    and regulations from state and local governments designed to protect health,
                    safety, and the environment. A summary of the major federal regulations
                    affecting the agricultural chemical industry follows.

       Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

     ;  ,    .         Every regulation promulgated under FIFRA affects the agricultural chemical
                    industry in some way.  The FIFRA regulations are found in 40 CFR Parts 152
                    through 186. Each part and its title are listed below.

                     Part 152 -    Pesticide Registration and Classification Procedures
                     Part 153 -    Registration Policies and Interpretations
                     Part 154 -    Special Review Procedures
                     Part 155 -    Registration Standards
                     Part 156 -    Labeling Requirements for Pesticides and Devices
                     Part 157 -    Packaging Requirements for Pesticides and Devices
                     Part 158 -    Data Requirements for Registration
                     Part 160 -    Good Laboratory Practice Standards
                     Part 162 -    State Registration of Pesticide Products
                     Part 163 -    Certification of Usefulness of Pesticide Chemicals
                     Part 164 -    Rules of Practice Governing Hearings, Under FIFRA,
                                  Arising from Refusals to Register, Cancellations of
                                  Registrations, Changes of Classifications, Suspensions of
                                  Registrations and Other Hearings Called Pursuant to
                                  section 6 of the Act
                     Part 166 -    Exemption of Federal and State Agencies for Use of
                                  Pesticides Under Emergency Conditions
                     Part 167 -    Registration of Pesticide and Active Ingredient Producing
                                  Establishments, Submission of Pesticide Reports
                     Part 168 -    Statements of Enforcement Policies and Interpretations
                     Part 169 -    Books and Records of Pesticide Production and
                                  Distribution
                     Part 170 -    Worker Protection Standards
                     Part 171 -    Certification of Pesticide Applicators
                     Part 172 -    Experimental Use Permits
                     Part 173 -    Procedures Governing the Rescission of State Primary
                                  Enforcement Responsibility for Pesticide Use Violations
                     Part 177 -    Issuance of Food Additive Regulations
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                      Part 178 -    Objections and Requests for Hearings
                      Part 179 -    Formal Evidentiary Public Hearing
                      Part 180 -    Tolerances and Exemptions from Tolerances for Pesticide
                                    Chemicals in or on Raw Agricultural Commodities
                      Part 185 -    Tolerances for Pesticides in Food
                      Part 186-    Pesticides in Animal Feed

                     Please refer to the general discussion of FIFRA in Section VI. A for additional
                     requirements not discussed below.

                     Product Registration Data Requirements
                     EPA requires the citation or submission of extensive environmental, health,
                     and/or safety data during the registration application process. The categories
                     of data required include the product's chemistry; environmental fate; residue
                     chemistry, hazards to humans, domestic animals, and nontarget organisms;
                     spray drift characteristics; reentry protection requirements; and performance
                     (40 CFR Part 158). Under the "product chemistry" category, applicants must
                     supply  technical  information describing the  product's  active  and inert
                     ingredients, manufacturing or  formulating  processes and physical and
                     chemical characteristics. Data from "environmental fate" studies are used to
                     assess the effects of pesticide residues on the environment, including its
                     toxicity to people through consumption or exposure to applied areas and its
                     effect on  nontarget organisms and  their habitat.   Residue chemistry
                     information includes  the  expected frequency,  amounts,  and  time  of
                     application, and test results of residue remaining on treated food or feed.
                     Information under "hazards to humans, domestic animals, and non-target
                     organisms" includes specific test data assessing  acute, subchronic, and
                     chronic toxicity.  All studies  required to be submitted must satisfy  Good
                     Laboratory Practice (GLP) regulations  (40 CFR Part 160). Guidelines for
                     studies  of product chemistry, residue chemistry, environmental chemistry,
                     hazard evaluation and occupational and residential exposure can be found in
                     40 CFR Part 158.

                     Registration of Establishments
                     Any person producing a pesticide or device, except a custom blender,4 is
                     subject to section 7 and 40 CFR. Part  167; and is required to register his
 A custom blender means any establishment which provides the service of mixing pesticides to a customer's
specifications, usually a pesticide(s)-fertilizer(s), pesticide-pesticide, or a pesticide animal feed mixture, when: (1)
The blend is prepared to the order of the customer and is not held in inventory by the blender; (2) the blend is to be
used on the customer's property (including leased or rented property); (3) the pesticide(s) used in the blend bears
end-use labeling directions which do not prohibit use of the product in such a blend; (4) the blend is prepared from
registered pesticides; (b) the blend is delivered to the end-user along with a copy of the end-use labeling of each
pesticide used in the blend and a statement specifying the composition of mixture; and (6) no other pesticide
production activity is performed at the establishment.
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                    establishment  with  EPA  prior  to   beginning   production.  Foreign
                    establishments also must register with EPA if they produce a pesticidal
                    product for import to the United States. Establishments must be registered
                    with EPA if they intend that a substance produced will be used as an active
                    ingredient of a pesticide or if they have actual or constructive notice that the
                    substance will be used as an active ingredient. If a pesticide is produced for
                    export, whether registered  or unregistered, or is produced under  an
                    experimental use permit, the producing establishment must be registered.

                    In order to register an establishment with EPA, contact the EPA Regional
                    office where the establishment is located, or for a foreign establishment, the
                    Washington, DC EPA office. The following information must be submitted
                    on EPA Form 3540-1 when registering an establishment: (1) the name and
                    address of the company; (2) the type of ownership; and (3) the name and
                    address of each producing establishment for which registration is sought.
                    Any changes to the information provided must be submitted to EPA within
                    thirty days after such changes occur.  Upon receiving a complete application,
                    EPA will assign a registration number for each listed establishment.  This
                    number must appear on the label.

                    Establishment Reporting Requirements
                    Under section 7(c)and 40 CFR. section 167.85, each registered pesticide
                    producing establishment must submit an annual production report to EPA by
                    March 1  of each year.  Domestic establishments submit their report to the
                    EPA regional office where the company headquarters is located.  Foreign
                    establishment production reports are submitted to the Washington, DC EPA
                    office. Custom blenders are exempt from this requirement.

                    The report must cover any pesticide, active ingredient, or device produced.
                    The report, to be submitted on specific EPA forms, includes the following
                    information: (1) the name and address of the establishment; (2) the amount
                    of each pesticide produced, repackaged, or relabeled in the past year; (3) the
                    amount of each pesticide sold, distributed, or exported in the past year; and
                    (4) the amount of the pesticide estimated to be produced, repackaged, or
                    relabeled in the current year. Foreign establishments only are  required to
                    submit a report on pesticides imported into the United States.

                    Maintenance of Records
                    All producers of pesticides, devices, or active ingredients used in producing
                    any pesticide must maintain records concerning the production and shipment
                    of each pesticide under 40 CFR Part 169. These records are independent of
                    other required records,  including in-plant maintenance, extermination, or
                    sanitation programs. Each establishment must maintain these records for two
                    years.  In addition, records on disposal methods must be maintained for 20
                    years, as well as authorized human trials. Records containing research data
                    must be maintained as long as the registration is valid and the producer is in
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                     business. All required records must be available if requested by an inspector.

                     Prior Informed Consent
                     As part of its participation in a voluntary international program known as the
                     Prior Informed Consent procedure, EPA prepares the following lists of
                     pesticides that are suspended, canceled or severely restricted.  These lists
                     were last updated by EPA in August of 1997.

                     A "Suspended or Canceled" pesticide is defined as a pesticide for which all
                     registered uses have been prohibited by final government action, or for which
                     all requests for registration or equivalent action for all uses have, for health
                     or environmental reasons, not been granted.

                     •  Suspended or Canceled

                       1.  aldrin
                       2.  benzene hexachloride [BHC] (voluntary cancellation)
                       3.  2,3,4,5-Bis(2-burylene)tetrahydro-2-furaldehyde [Repellent-11]
                       4.  bromoxynil butyrate (voluntary cancellation)
                       5.  cadmium compounds (voluntary cancellation)
                       6.  calcium arsenate (voluntary cancellation)
                       7.  captafol (voluntary cancellation)
                       8.  carbon tetrachloride
                       9.  chloranil (voluntary cancellation)
                      10.  chlordane
                      11.  chlordimeform (voluntary cancellation)
                      12.  chlorinated camphene [Toxaphene] (voluntary cancellation)
                      13.  chlorobenzilate (voluntary cancellation)
                      14.  chloromethoxypropylmercuric acetate [CPMA]
                      15.  copper arsenate (voluntary cancellation)
                      16.  cyhexatin (voluntary cancellation)
                      17.  DBCP
                      18.  decachlorooctahydro-1,3,4-metheno-2H-cyclobuta(cd) pentalen-2-
                             onefchlordecone]
                      19.  DDT
                      20.  dieldrin
                      21.  dinoseb and salts
                      22.  Di(phenylmercury)dodecenylsuccinate [PMDS] (voluntary
                             cancellation)
                      23.  EDB
                      24.  endrin (voluntary cancellation)
                      25.  EPN (voluntary cancellation)
                      26.  ethyl hexyleneglycol [6-12] (voluntary cancellation)
                      27.  hexachlorobenzene [HCB] (voluntary cancellation)
                      28.  lead arsenate (voluntary cancellation)
                      29.  leptophos (Never received initial registration)
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                      30. mercurous chloride
                      31. mercuric chloride
                      32. mevinphos
                      33. mirex (voluntary cancellation)
                      34. monocrotophos (voluntary cancellation)
                      35. nitrofen (TOK) (voluntary cancellation)
                      36. OMPA (octamethylpyrophosphoramide)
                      37. phenylmercury acetate [PMA]
                      38. phenylmercuric oleate [PMO] (voluntary cancellation)
                      39. potassium 2,4,5-trichlorophenate [2,4,5-TCP] '
                      40. pyriminil [Vacor] (voluntary cancellation)
                      41. safrole (voluntary cancellation)
                      42. silvex
                      43. sodium arsenite
                      44. TDE (voluntary cancellation)
                      45. Terpene polychlorinates [Strobane] (voluntary cancellation)
                      46. thallium sulfate
                      47. 2,4,5-Trichlorophenoxyacetic acid [2,4,5-T]
                      48. vinyl chloride

                     A "Severely Restricted" pesticide means a pesticide for which virtually all
                     registered uses have been prohibited by final government regulatory action,
                     but for which certain specific registered use or uses remain authorized.

                     •  Severely Restricted

                       1. arsenic trioxide
                       2. azinphos methyl
                       3. carbofuran (voluntary cancellation)
                       4. daminozide (voluntary cancellation)
                       5. heptachlor
                       6. methyl parathion
                       7. sodium arsenate
                       8. tributyltin compounds

       Federal Food, Drug, and Cosmetics Act

                     Under the  Federal Food, Drug, and Cosmetics Act (FFDCA),  EPA sets
                     tolerances for pesticide residues in food. This authority originally belonged
                     to the Food and Drug Administration (FDA), but was transferred when EPA
                     was formed in 1970. FDA still has responsibility for enforcing compliance
                     with the tolerances. An agricultural  product is deemed unsafe  under the
                     FFDCA if it contains pesticide residues above the tolerance level established
                     by EPA or if there is no tolerance, unless it is exempt from the requirement
                     for tolerances.
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                    The FFDCA also contains the Delaney Clause that bars the establishment of
                    food additive regulations covering substances that induce cancer in humans
                    or animals. Prior to the Food Quality Protection Act of 1996, this provision
                    applied to certain pesticide residues in processed food. With the  1996
                    amendments, pesticide residues are now governed by a single safety clause
                    set forth in section 408.
       Toxic Substances Control Act (TSCA)

                    TSCA gives  EPA  comprehensive authority  to  regulate any chemical
                    substance whose manufacture, processing, distribution in commerce, use, or
                    disposal  may  present an  unreasonable risk of injury to health or the
                    environment. EPA keeps an inventory of existing chemicals regulated under
                    TSCA (TSCA section 8(b)). Certain chemicals are specifically excluded
                    from the TSCA inventory, such as pesticides, as defined when manufactured,
                    processed, or distributed in commerce for use as a pesticide under FIFRA (40
                    CFR section 710.2(h)(2)). However, if a chemical has multiple uses, those
                    uses not subject to FIFRA are regulated by TSCA.  In addition, certain
                    mixtures of chemicals are exempt from TSCA (40 CFR section 710.2(h)(l))
                    (Landfair, 1993).

                    Four sections are of primary importance to the remainder of the agricultural
                    chemical industry. Section 5 mandates that chemical companies submit to
                    EPA pre-manufacture notices  that provide information on  health and
                    environmental effects for each new product and test existing products for
                    these effects (40 CFR Part 720). Over 20,0.00 premanufacture notices have
                    been filed. Section 4 authorizes EPA to require testing of certain substances
                    (40 CFR Part 790). Section 6 gives EPA the authority to prohibit, limit, or
                    ban the manufacture, process, and usage of chemicals (40 CFR Part 750).
                    Among the chemicals  EPA regulates  under section 6 are  asbestos,
                    chlorofluorocarbons (CFCs), and polychlorinated biphenyls (PCBs). For
                    certain chemicals; TSCA section 8 also imposes record-keeping and reporting
                    requirements including substantial risk notification; record-keeping for data
                    relative to adverse reactions; and periodic updates to the TSCA Inventory.

       Resource Conservation and Recovery Act (RCRA)

                    The Resource Conservation and Recovery Act (RCRA) was enacted in 1976
                    to address problems related to hazardous and solid waste management.
                    RCRA gives EPA the authority to establish a list of solid and hazardous
                    wastes and to establish standards and regulations for the treatment, storage,
                    and disposal of these wastes. Regulations in Subtitle C of RCRA address the
                    identification, generation, transportation, treatment, storage, and disposal of
                    hazardous wastes. These regulations are found in 40 CFR Part 124 and CFR
                    Parts 260-279. Under RCRA, persons who generate waste must determine
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                    whether the waste is defined as solid waste or hazardous waste. Solid wastes
                    are considered hazardous wastes if they are listed by EPA as hazardous or if
                    they exhibit characteristics of a hazardous waste: toxicity,  ignitability,
                    corrosivity, or reactivity.

                    Products, intermediates, and off-specification products potentially generated
                    at agricultural chemical facilities that are considered hazardous wastes are
                    listed in 40 CFR Part 261. Some of the handling and treatment requirements
                    for RCRA hazardous waste generators are covered under 40 CFR Part 262
                    and include the following: determining what constitutes a RCRA hazardous
                    waste (Subpart A); manifesting  (Subpart B);  packaging, labeling, and
                    accumulation time limits (Subpart C); and record keeping and reporting
                    (Subpart D).

                    Many agricultural chemical facilities store some hazardous wastes at the
                    facility beyond the accumulation time limits available to generators (e.g., 90
                    or 180 days). Such facilities are required to have a RCRA treatment, storage,
                    and disposal facility (TSDF) permit (40 CFRPart 262.34). Some agricultural
                    chemical facilities are considered TSDF facilities and are subj ect to a number
                    of regulations, including but not limited to those covered under 40 CFR Part
                    264: contingency plans and emergency procedures (40 CFR Part 264 Subpart
                    D); manifesting, record keeping, and reporting (40 CFR Part 264 Subpart E);
                    use and management of containers (40 CFR Part 264 Subpart I); tank systems
                    (40 CFR Part 264 Subpart J); surface impoundments (40 CFR Part 264
                    Subpart K); land treatment (40 CFR Part 264 Subpart M); corrective action
                    of hazardous  waste releases (40 CFR Part 264  Subpart S); air emissions
                    standards for process vents of processes that process or generate hazardous
                    wastes (40 CFR Part 264  Subpart AA);  emissions standards  for leaks in
                    hazardous waste handling equipment (40 CFR Part 264 Subpart BB); and
                    emissions standards for containers, tanks, and surface impoundments that
                    contain hazardous wastes (40 CFR Part 264 Subpart CC).

                    Many agricultural chemical facilities are also subject to the underground
                    storage tank (UST) program (40 CFR Part 280). The UST regulations apply
                    to facilities that  store either petroleum products or hazardous substances
                    (except hazardous waste) identified under the Comprehensive Environmental
                    Response, Compensation, and Liability Act. UST regulations address design
                    standards, leak detection, operating practices, response to releases, financial
                    responsibility for releases, and closure standards.

                    A number of RCRA wastes have been prohibited from land disposal unless
                    treated to meet specific standards under the RCRA Land Disposal Restriction
                    (LDR) program. The wastes covered by the RCRA LDRs are listed in 40
                    CFR Part 268  Subpart C and include a number of  wastes that could
                    potentially be generated at agricultural chemical facilities. Standards for the
                    treatment and storage of restricted wastes are described in Subparts D and E,
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                    respectively.

                    The LDRs also apply to the use of fertilizers containing hazardous wastes.
                    Therefore, fertilizers containing hazardous wastes that do not meet the
                    applicable land disposal treatment standards cannot be spread on the land,
                    with some exceptions. Specific exemptions to the use of certain recycled
                    materials and hazardous wastes in fertilizers have been provided in 40 CFR
                    Part 266,  Subpart C - Recycled Materials Used in a Manner Constituting
                    Disposal.  Subpart C states that products containing recyclable materials are
                    not subject to regulation under RCRA if the recyclables are physically
                    inseparable from the product or if they meet the standards of 40 CFR Part
                    268, Subpart D "for each recyclable material (i.e., hazardous waste) that they
                    contain."  These standards include limits on heavy metals. Subpart C also
                    states that zinc-containing fertilizers using hazardous waste K061 (emission
                    control dust/sludge from the primary production of steel in electric furnaces)
                    which is listed as hazardous due  to its hexavalent chromium, lead, and
                    cadmium content, are not subject to the land disposal requirements.

       Comprehensive Environmental Response, Compensation,  and Liability Act (CERCLA)

                    The Comprehensive Environmental Response, Compensation, and Liability
                    Act of 1980 (CERCLA) and the Superfund Amendments andReauthorization
                    Act of 1986  (SARA) provide  the  basic legal framework for the federal
                    "Superfund" program to clean up abandoned hazardous waste sites (40 CFR
                    Part 300 et seq.). The 1986 SARA legislation extended CERCLA taxes for
                    five years and adopted a new broad-based corporate environmental tax,
                    applicable to the allied chemicals (SIC 28) industry, which includes the
                    agricultural  chemical  industry.  In  1990,  Congress  passed  a simple
                    reauthorization that did not substantially change the law but extended the
                    program authority until 1994 and the taxing authority until the end of 1995.
                    A comprehensive reauthorization was considered in 1994, but not passed.
                    Since the expiration of the taxing authority on December 31,1995, taxes for
                    Superfund have been temporarily suspended.  The taxes  can only be
                    reinstated by reauthorization of Superfund or an omnibus reconciliation act
                    which could specifically reauthorize taxing authority. The allied chemical
                    industry paid about $300 million a year in Superfund chemical feedstock
                    taxes.  Joint and several liability generally requires Potentially Responsible
                    Parties (PRPs) to perform or pay for their fair share of cleanup costs.

                    Title III of the 1986 SARA amendments (also known as Emergency Response
                    and Community Right-to-Know Act, EPCRA) requires all manufacturing
                    facilities,  including agricultural  chemical facilities,  to report annual
                    information  about stored toxic substances, as well as  release of  these
                    substances into the environment, to local and state governments and to the
                    public. This is known as the Toxic Release Inventory (TRI).  EPCRA also
                    establishes requirements for federal, state, and local governments regarding
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                    emergency planning. In 1994, over 300 more chemicals were added to the
                    list of chemicals for which reporting is required.

       Clean Air Act (CAA)

                    The original CAA authorized EPA to  set limits on agricultural chemical
                    facility emissions.  The new source performance standards (NSPS) for
                    fertilizer manufacturers can be found in 40 CFR Part 60:
                     Subpart G -   Standards of Performance for Nitric Acid Plants
                                   (40 CFR section 60.70 - 60.74)

                     Subpart T -   Standards of Performance for the Phosphate Fertilizer
                                   Industry: Wet Process Phosphoric Acid Plants
                                   (40 CFR section 60.200 - 60.204)

                     Subpart U -   Standards of Performance for the Phosphate Fertilizer
                                   Industry: Superphosphoric Acid Plants
                                   (40 CFR section 60.210 - 60.214)

                     Subpart V -   Standards of Performance for the Phosphate Fertilizer
                                   Industry: Diammonium Phosphate Plants
                                   (40 CFR section 60.220 - 60.224)

                     Subpart W -.  Standards of Performance for the Phosphate Fertilizer
                                   Industry: Triple Superphosphate Plants
                                   (40 CFR section 60.230 - 60.234)

                     Subpart X -.   Standards of Performance for the Phosphate Fertilizer
                                   Industry: Granular Triple Superphosphate Storage
                                   Facilities (40 CFR section 60.240 - 60.244)

                    These standards primarily consist of emission and monitoring standards for
                    nitrogen oxides (Nitric Acid Plants) and fluorides (Phosphatic Fertilizer
                    Industry).

                    The Clean Air Act Amendments of 1990 set National Emission Standards for
                    Hazardous  Air Pollutants  (NESHAP) from industrial  sources  for 41
                    hazardous air pollutants to be met by 1995 and for 148 other hazardous air
                    pollutants to be reached by 2003.  National emission standards for new and
                    existing  major sources in phosphoric acid manufacturing, phosphate
                    fertilizers production and pesticide active ingredient production are listed in
                    40 CFR Parts 9 and 63. 40 CFR Parts 61 and 63 contains several provisions
                    dealing with emissions sources potentially found at an agricultural chemical
                    facility (e.g. equipment leaks, tanks, surface impoundments, separators, and
                    waste treatment operations) may affect the agricultural chemical industry. A
                    number of  the chemicals used  and produced  at agricultural chemical
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                    manufacturing and formulating facilities are hazardous air pollutants under
                    CAA.

                    Under section 112(r) of CAA, owners and operators of stationary sources
                    who produce, process, handle, or store substances listed under CAA section
                    112(r)(3) or any other extremely hazardous substance have a "general duty"
                    to initiate specific activities to prevent and mitigate accidental releases. Since
                    the general duty requirements apply to stationary sources regardless of the
                    quantity of substances managed at the facility, many agricultural chemical
                    manufacturing  and formulating facilities are subject.  Activities such as
                    identifying hazards  which  may  result from  accidental releases  using
                    appropriate  hazard assessment techniques;  designing, maintaining  and
                    operating  a safe facility; and minimizing the consequences of accidental
                    releases if they occur are considered essential activities to satisfy the general
                    duty requirements. These statutory requirements have been in affect since the
                    passage of the Clean Air Act in 1990. Although there is no list of "extremely
                    hazardous substances," EPA's Chemical Emergency Preparedness  and
                    Prevention   Office   provides   some   guidance  at   its   website:
                    http://www.epa.gov/swercepp.html.

                    Also under section! 12(r), EPA was required to develop a list of at least 100
                    substances that, in the event of an accidental release,  could cause death,
                    injury, or  serious adverse effects to human health or the environment.  The
                    list promulgated by EPA is contained in 40 CFR section 68.130 and includes
                    acutely toxic chemicals, flammable gases and volatile  flammable liquids.
                    Under section 112(r)(7), facilities handling more than a threshold quantity
                    (ranging from 500 to 20,000 pounds) of these substances are subject to
                    chemical  accident prevention provisions including the development and
                    implementation of a risk management program (40 CFR sections 68.150-
                    68.22Q). The requirements in 40 CFR Part 68 begin to go into effect in June
                    1999. Many of the chemicals on the  112(r) list are commonly handled by
                    agricultural chemical manufacturers and formulators in quantities greater than
                    the threshold values. Ammonia held by farmers for use as an agricultural
                    nutrient is exempt from the chemical accident prevention provisions.

                    Standards in 40 CFR Part 61 Subpart R - National Emission Standards for
                    Radon Emissions from Phosphogypsum Stacks (40 CFR sections 61.200 -
                    61.210) deal specifically with the phosphatic fertilizer industry.   The
                    standards require monitoring and reporting of radon-222 emissions from the
                    stacks and sets limits on the amounts of radon-222 that can be emitted into
                    the air.  EPA has also set standards for the maximum concentration of
                    radium-226 allowed in phosphogypsum removed from stacks for use in
                    agriculture.

       Clean Water Act (CWA)
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                    The Clean Water Act, first passed in 1972 and amended in 1977 and 1987,
                    gives EPA the authority to regulate effluents from sewage treatment works,
                    chemical plants, and other  industrial sources  into waters.  The act sets
                    standards for treatment of wastes for both direct and indirect (to a Publicly.
                    Owned  Treatment Works (POTW)) discharges.   EPA has set effluent
                    guidelines for both the fertilizer manufacturing and formulating, and pesticide
                    formulating, packaging  and repackaging  point source categories.   The
                    implementation of the guidelines is left primarily to the states who issue
                    National Pollutant Discharge Elimination System (NPDES) permits for each
                    facility (EPA has authorized 43 'states to operate the NPDES program).

                    Effluent guidelines specific to the fertilizer manufacturing and formulating
                    point source category are contained in 40 CFR Part 418 and are divided into
                    product specific effluent guidelines as follows:
                     Subpart A -   Phosphates (40 CFR section 418.10-418.17)

                     Subpart B -   Ammonia (40 CFR section 418.20 - 418.27)

                     Subpart C-   Urea (40 CFR section 418.30-418.36)

                     Subpart D -   Ammonium Nitrate (40 CFR section 418.40 - 418.46)

                     Subpart E -   Nitric Acid (40 CFR section 418.50 - 418.56)

                     Subpart F -   Ammonium Sulfate (40 CFR section 418.60 - 418.67)

                     Subpart G -   Mixed and Blend Fertilizer Production
                                  (40 CFR section 418.70-418.77)

                    In 1997,  revised effluent  guidelines  were  finalized for the Pesticide
                    Formulating, Packaging and Repackaging Subcategory. These regulations
                    replace  the effluent guidelines established  in 1978  for the Pesticide
                    Formulating and Packaging  Subcategory.   The revised guidelines are
                    contained in 40 CFR Part  455  and  are  divided into the following
                    subcategories:
                     Subpart C -     Pesticide Chemicals Formulating and Packaging
                                    Subcategory

                     Subpart E -     Repackaging of Agricultural Pesticides Performed at
                                    Refilling Establishments
                    Each Subpart consists of effluent standards  representing the amount of
                    effluent  reduction  possible  by using either  best practicable  control
                    technologies (BPT), best conventional pollution technologies (BCT), or best
                    available technologies (BAT). The states and  EPA give effect to these
                    standards through NPDES permits that they issue to direct dischargers. BCT
                    standards limit the discharge of conventional pollutants, while BPT and BAT
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                     standards represent successive levels of control of priority pollutants and
                     non-conventional pollutants.

                     For Subcategory C, EPA established effluent limitations and pretreatment
                     standards which allow each facility a choice of meeting a zero discharge
                     limitation or to comply with a pollution prevention alternative that authorizes
                     the  discharge  of some pesticide active ingredients (AIs) and priority
                     pollutants  after various  pollution prevention practices  are  followed and
                     treatment is conducted as needed. For Subcategory E, EPA has established
                     a zero discharge limitation and pretreatment standard.

                     The  Storm  Water Rule (40  CFR  section  122.26)  requires  fertilizer
                     manufacturing  and  formulating and  pesticide formulating  facilities
                     discharging storm water associated with industrial activities (40 CFR section
                     122.26 (b)(14)(ii)) to apply for NPDES permits for those discharges.

                     Under 40 CFR 503 Subpart B - Land Application, EPA regulates the land
                     application of sewerage treatment sludge, which includes fertilizers derived
                     from sewerage  treatment sludge.  Subpart B regulations  include specific
                     limitations on heavy metal content,  as  well as  general  operational and
                     management standards.
VI.C. State Regulation of Pesticides
                     All states have their own pesticide laws and many states have their own
                     pesticide registration requirements.  States have primary use enforcement
                     authority if EPA has determined that the state has adequate pesticide use laws
                     and has adopted adequate procedures to enforce those laws. The EPA may
                     enter into a cooperative agreement with a state to carry out enforcement of
                     state laws  and train and certify  applicators.  The FIFRA allows states to
                     administer their own EP A-approved applicator certifications program. Also,
                     each state is allowed to regulate the sale and use of pesticides as long as the
                     regulations are at least as  stringent as EPA's and the regulations do not
                     conflict or differ from EPA's labeling and packaging restrictions.

                     States typically require that fertilizer products be registered with the state and
                     that claims made on fertilizer labels can be substantiated. States also regulate
                     the efficacy of fertilizers  through labeling requirements. State fertilizer
                     labeling requirements typically require that the label  indicate the product
                     name, the brand  and  grade, the  percentage  of each nutrient (nitrogen,
                     available phosphate, potassium, etc.), and the name and address of the
                     registrant.   Some  states also require  that the label indicate materials from
                     which the nutrients are derived.

                     Additional information on specific state requirements can be obtained from
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                    the Association of American Pesticide Control Officials, Inc. (AAPCO) at:
                    http://aapco.ceris.purdue.edu/index.html.  This website contains a list of
                    state pesticide control officials that includes contact information.
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VI.D. Pending and Proposed Regulatory Requirements

       FIFRA
                    Registration
                           In order to reduce the potential for groundwater contamination from
                           certain pesticides,  EPA  proposed the Ground Water Pesticide
                           Management Plan Rule in June of 1996 (61  FR 33259).  EPA is
                           proposing to restrict the use of certain pesticides by providing states
                           and tribes with the flexibility to protect the ground water in the most
                           appropriate way for local conditions, through the development and
                           use of Pesticide  Management Plans (PMPs). When finalized, the
                           regulations will likely give states and tribes the authority to develop
                           management plans that specify risk reduction measures for the
                           following  four  pesticides:  atrazine,  alachlor,   simazine,  and
                           metolachlor. Without EPA-approved plans, use of these chemicals
                           would be prohibited. A final rule is expected to be published in late
                           2000.  (Contact:  Arty Williams,  United States  EPA Office  of
                           Prevention, Pesticides and Toxic Substances, 703-305-5239)

                           In response to the Food Quality Protection Act of 1996, EPA is
                           planning to propose revisions  to antimicrobial  registration and
                           classification procedures (40 CFR Part 152) that will reduce to the
                           extent possible  the review  time for  antimicrobial pesticides.
                           Revisions to labeling requirements (40 CFR Part 156)  and data
                           requirements for antimicrobial  registration (40 CFR Part  158) are
                           also being proposed. The revisions are expected to be released in
                           early 2001. This regulation would also implement some general
                           provisions of FIFRA that pertain to all pesticides, including labeling
                           requirements and notification procedures. (Contact:  Jean Frane,
                           United States EPA Office of Prevention, Pesticides, and Toxic
                           Substances, 703-305-5944  and  Paul  Parsons, United States  EPA
                           Office of Prevention, Pesticides, and Toxic Substances, 703-308-
                           9073)

                           In order  to evaluate the registrability of pesticide products, EPA is
                           expected to propose revisions to the data requirements for FIFRA
                           registration (40 CFR Part 158). These revisions would clarify all data
                           requirements to reflect current practice and are  expected  to  be
                           published in 2001. (Contact: Jean Frane, United States EPA Office of
                           Prevention, Pesticides, and Toxic Substances, 703-305-5944)

                     Use Restrictions
                     •     In May of 1991, EPA proposed amendments to the existing Restricted
                           Use Classification (RUG) regulations (40 CFR Part 152, Subpart I)
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            Federal Statutes and Regulations
                           to add criteria pertaining to the groundwater contamination potential
                           of pesticides (56 FR 22076). The criteria would be used to determine
                           which  pesticides  should  be  considered  for  restricted  use
                           classifications to protect groundwater. A policy statement is expected
                           to be issued in late 2000. (Contact: Joseph Hogue, United States EPA
                           Office of Prevention, Pesticides, and Toxic Substances, 703-308-
                           9072)

                    Tolerances and Exemptions
                    •      EPA expects to reassess pesticide tolerances and exemptions for raw
                           and processed foods established prior to August 3,1996 (40 CFR Part
                           180,40 CFR Part 185,40 CFR Part 186), to determine whether they
                           meet the standard of the Federal Food, Drug and Cosmetic Act
                           (FFDCA). FFDCA section 408 (q), as amended by the Food Quality
                           Protection Act, requires that EPA conduct this reassessment on a
                           phased 10-year schedule. For the current phased schedule, EPA is
                           required to complete reassessments as follows: 33% by August 3,
                           1999, 66% by August 3, 2002, and 100% by August 3, 2006. Based
                           on its reassessment, EPA will likely propose a series of regulatory
                           actions to modify or revoke tolerances. (Contacts: Robert McNally,
                           United States EPA, Office  of Prevention,  Pesticides and Toxic
                           Substances, 703-308-8085 and Joseph Nevola, United States EPA
                           Office of Prevention Pesticides and Toxic Substances, 703-308-8037)
                           Regulations specifying policies and procedures under which the EPA
                           can establish food tolerances associated with the use of pesticides
                           under emergency exemptions (40 CFR Part 176) are expected to be
                           finalized in late 2000. The EPA issues emergency exemptions for
                           temporary use of pesticides where emergency conditions exist. Under
                           FFDCA, as amended by the Food Quality Protection Act, EPA must
                           establish time-limited tolerances for such pesticides if the use is likely
                           to result in residues in food. (Contact: Joseph Hogue, United States
                           EPA Office of Prevention, Pesticides, and Toxic Substances, 703-
                           308-9072)

                           EPA proposed a rule to adjust and update the fee structure and fee
                           amounts for tolerance actions, which are required under FFDCA (40
                           CFR section 180.33). The rule is expected to finalized in late 2000.
                           (Contact: Carol Peterson, United States EPA, Office of Prevention,
                           Pesticides, and Toxic Substances, 703-305-6558)

                           Revisions to regulations on emergency exemptions under section 18
                           of FIFRA, are expected to be issued in late 2001 (40 CFR Part 166).
                           EPA is considering revisions in four areas: 1) Options for increased
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             Federal Statutes and Regulations
                           authority for states to administer certain aspects of the exemption
                           process, and/or increased use by the EPA of multi-year exemptions;
                           2) the use of emergency exemptions to address pesticide resistance;
                           3) the possibility of granting exemptions based upon reduced risk
                           considerations; and  4)  definitions  of emergency situation and
                           significant economic loss, which would affect whether or not an
                           exemption may be granted.  (Contact: Joseph Hogue, United States
                           EPA Office  of Prevention, Pesticides, and Toxic Substances, 703-
                           308-9072)

                    Pesticide Storage and Disposal
                    •      In 1994, EPA proposed a rule, authorized under section 19 of FIFRA,
                           to establish standards for pesticide containers  and secondary
                           containment relating to the distribution and sale of pesticides (59 FR
                           6712). Standards are expected to be developed for the removal of
                           pesticides from containers, rinsing containers,   container design,
                           container labeling, container refilling, the containment of stationary
                           bulk containers and for the containment of pesticide dispensing areas
                           (40 CFR Part 165, 40 CFR Part 156).  A final rule is expected to be
                           published in late 2000. (Contact: Nancy Fitz, United States EPA,
                           Office of Prevention, Pesticides and Toxic  Substances, 703-305-
                           7385)

                    Exports
                    •      The Rotterdam Agreement, signed in 1998, requires that certain
                           banned or severely  restricted hazardous chemicals are subject to
                           intensive information exchange procedures, and if an importing
                           country decides against import, exporting countries are obligated to
                           prohibit export to that country. Twenty-four pesticides are currently
                           covered by the treaty. As a result of the United States signing of this
                           treaty, EPA has drafted legislation that allows it in  the future to
                           propose revisions to its pesticide export policy.  (Contact: Cathleen
                           Barnes,'United States EPA Office of Prevention, Pesticides and Toxic
                           Substances, 703-305-7101)

                    Worker Protection
                    •      EPA has proposed a change to the Worker Protection  Standards
                           (WPS)  of FIFRA (40 CFR  Part  170).  Specifically, the glove
                           requirements may be modified to allow glove liners to be worn inside
                           chemically resistant gloves. The proposed rule will be finalized in
                           2001.  (Contact:  Kevin  Keaney, United States EPA Office of
                           Prevention, Pesticides and Toxic Substances, 703-305-5557)
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       Compliance and Enforcement History
VII. COMPLIANCE AND ENFORCEMENT HISTORY

       Background

                    Until recently, EPA has  focused much of its  attention  on measuring
                    compliance with specific environmental statutes. This approach allows the
                    Agency to track compliance with the Federal Insecticide, Fungicide, and
                    Rodenticide Act, the Clean Air Act, the Resource Conservation and Recovery
                    Act, the Clean Water Act, and other environmental statutes. Within the last
                    several years, the Agency has begun to supplement single-media compliance
                    indicators with facility-specific, multimedia indicators of compliance.  In
                    doing so, EPA is in a better position to track compliance with all statutes at
                    the facility level, and within specific industrial sectors.

                    A major step in building the capacity to compile multimedia data for
                    industrial sectors was the creation of EPA's Integrated Data for Enforcement
                    Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's
                    single-media databases, extract compliance records, and match the records to
                    individual  facilities.  The IDEA system can match Air, Water, Waste,
                    Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
                    facility, and generate a list of historical permit, inspection, and enforcement
                    activity. IDEA also has the capability to analyze data by geographic area and
                    corporate holder. As the capacity to generate multimedia compliance data
                    improves,  EPA  will  make available  more  in-depth  compliance  and
                    enforcement information. Additionally, sector-specific measures of success
                    for compliance assistance efforts are under development.

       Compliance and Enforcement Profile Description

                    Using inspection, violation and enforcement data from the IDEA system, this
                     section provides information  regarding the historical  compliance  and
                     enforcement activity of this sector. In order to mirror the facility universe
                    reported in the Toxic Chemical Profile, the data reported within this section
                     consists of records only from the TRI reporting universe. With this decision,
                    the selection criteria are consistent across sectors with certain exceptions.
                     For the sectors that do not normally report to the TRI program, data have
                     been provided from EPA's Facility Indexing System (FINDS) which tracks
                     facilities in all media databases. Please note, in this section, EPA does not
                     attempt to  define the actual number of facilities that fall within each sector.
                     Instead, the section portrays the records of a subset of facilities within the
                     sector that are well defined within EPA databases.

                     As a check on the relative size of the full sector universe, most notebooks
                     contain an estimated number of facilities within the sector according to the
                     Bureau of Census (See Section  II).   With sectors dominated  by small
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       Compliance and Enforcement History
                    businesses, such as metal finishers and printers, the reporting universe within
                    the EPA databases may be small in comparison to Census data. However, the
                    group selected for inclusion in this data analysis section should be consistent
                    with this sector's general make-up.

                    Following this  introduction is a list defining each data column presented
                    within this section.  These values represent a retrospective summary  of
                    inspections and enforcement actions, and reflect solely EPA, state, and local
                    compliance assurance activities that have been entered into EPA databases.
                    To identify any changes in trends, the EPA ran two data queries, one for the
                    past five calendar years (April 1,1992 to March 31,1997) and the other for
                    the most recent twelve-month period (April 1,1996 to March 31,1997). The
                    five-year analysis  gives an average level  of  activity for that period for
                    comparison to the more recent activity.

                    Because most inspections focus on single-media  requirements, the data
                    queries presented in this section are taken from single media databases.
                    These databases do not provide data on whether inspections are state/local or
                    EPA-led. However, the table breaking down the universe of violations does
                    give the reader a crude measurement of the EPA's and states' efforts within
                    each media program. The presented data illustrate the variations across EPA
                    regions for certain sectors.5 This variation may be attributable to state/local
                    data entry variations, specific  geographic concentrations, proximity  to
                    population centers, sensitive ecosystems, highly toxic chemicals  used  in
                    production, or historical noncompliance. Hence, the exhibited data do not
                    rank regional performance or necessarily reflect which regions may have the
                    most compliance problems.
Compliance and Enforcement Data Definitions

       General Definitions
                    Facility Indexing System (FINDS) ~ assigns a common facility number to
                    EPA single-media permit records. The FINDS identification number allows
                    EPA to compile and review  all permit, compliance, enforcement, and
                    pollutant release data for any given regulated facility.

                    Integrated Data for Enforcement Analysis (IDEA) -- is a data integration
                    system that can retrieve information from the major EPA program office
5 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD,
PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK,
TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X
(AK, ID, OR, WA)."
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       Compliance and Enforcement History
                    databases. IDEA uses the FINDS identification number to link separate data
                    records from EPA's databases.  This allows retrieval of records from across
                    media or statutes for any given facility, thus creating a "master list" of
                    records for that facility. Some of the data systems accessible through IDEA
                    are: AFS (Air Facility Indexing and Retrieval System, Office of Air and
                    Radiation), PCS (Permit Compliance  System, Office of Water), RCRIS
                    (Resource Conservation and Recovery Information System, Office of Solid
                    Waste), NCDB (National Compliance Data Base, Office of Prevention,
                    Pesticides, and Toxic Substances), CERCLIS (Comprehensive Environmental
                    and Liability Information System, Superfund), and TRIS (Toxic Release
                    Inventory System). IDEA also contains information from outside sources
                    such  as  Dun and Bradstreet  and the Occupational Safety and  Health
                    Administration (OSHA). Most data queries displayed in notebook sections
                    IV and VII were conducted using IDEA.

       Data Table Column Heading Definitions

                    Facilities in Search -- are based on the universe of TRI reporters within the
                    listed  SIC code range.  For industries not covered under TRI reporting
                    requirements (metal mining, nonmetallic mineral mining, electric power
                    generation, ground transportation, water transportation, and dry cleaning), or
                    industries in which only a very small fraction of facilities report to TRI (e.g.,
                    printing), the notebook uses the FINDS universe for executing data queries.
                    The SIC code range selected for each search is defined by each notebook's
                    selected SIC code coverage described in section II.

                    Facilities Inspected — indicates the level of EPA and  state  agency
                    inspections for the facilities in this data search.  These values show what
                    percentage of the facility universe is inspected in a one-year or five-year
                    period.

                    Number of Inspections  ~  measures the total number of inspections
                    conducted in this sector. An inspection event is counted each time it is
                    entered into a single media database.

                    Average Time Between Inspections ~ provides an average length of time,
                    expressed in months, between compliance inspections at a facility within the
                    defined universe.

                    Facilities with One or More Enforcement Actions -- expresses the number
                    of facilities that were the subj ect of at least one enforcement action within the
                    defined time period. This category is broken down further into federal and
                     state actions. Data are obtained for administrative, civil/judicial, and criminal
                     enforcement actions. Administrative actions include Notices of Violation
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        Compliance and Enforcement History
                     (NOVs). A facility with multiple enforcement actions is only counted once
                     in this column, e.g., a facility with 3 enforcement actions counts as 1 facility.

                     Total Enforcement Actions — describes the total number of enforcement
                     actions identified for an industrial sector across all environmental statutes.
                     A facility with multiple enforcement actions is counted multiple times, e.g.,
                     a facility with 3 enforcement actions counts as 3.

                     State Lead Actions —  shows what percentage of the total enforcement
                     actions are taken by state and local environmental agencies. Varying levels
                     of usage by states of EPA data systems may limit the volume of actions
                     recorded as state  enforcement  activity. Some  states extensively  report
                     enforcement activities into EPA data systems, while other states may use
                     their own data systems..

                     Federal Lead Actions ~ shows what percentage of the total enforcement
                     actions are taken by the United States Environmental Protection Agency.
                     This value includes referrals from state agencies. Many of these actions
                     result from coordinated or joint state/federal efforts.

                     Enforcement to Inspection Rate -- is a ratio of enforcement actions to
                     inspections, and is presented for comparative purposes only. This ratio is a
                     rough indicator of the relationship between inspections and enforcement. It
                     relates the number of enforcement actions and the number of inspections that
                     occurred within the one-year or five-year period. This ratio includes the
                     inspections and enforcement actions reported under the Clean Water Act
                     (CWA), the Clean Air Act (CAA) and the Resource Conservation and
                     Recovery Act (RCRA).  Inspections and actions from the TSCA/FIFRA/
                     EPCRA database are not factored into this ratio because most of the actions
                     taken under these programs are not the result of facility inspections. Also,
                     this ratio does not account for  enforcement actions arising  from non-
                     inspection  compliance  monitoring  activities (e.g., self-reported  water
                     discharges) that can result in enforcement action within the CAA, CWA, and
                     RCRA.

                     Facilities with One or More Violations  Identified  — indicates the
                     percentage of inspected facilities having a violation identified in one of the
                     following data categories:  In Violation or  Significant Violation  Status
                     (CAA);  Reportable  Noncompliance,  Current  Year > Noncompliance,
                     Significant Noncompliance (CWA); Noncompliance  and  Significant
                    Noncompliance (FIFRA, TSCA,  and  EPCRA); Unresolved Violation and
                     Unresolved High Priority Violation (RCRA).  The values presented for this
                     column reflect the extent of noncompliance within the measured time frame,
                     but do not distinguish between the severity of the noncompliance. Violation
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       Compliance and Enforcement History
                    status may be a precursor to an enforcement action, but does not necessarily
                    indicate that an enforcement action will occur.

                    Media Breakdown of Enforcement Actions and Inspections  -- four
                    columns identify the proportion of total inspections and enforcement actions
                    within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
                    column is a percentage of either the "Total Inspections," or the  "Total
                    Actions" column.

VILA. Fertilizer, Pesticide, and Agricultural Chemical Industry Compliance History

                    Table 25 provides an overview of the reported compliance and enforcement
                    data for the Fertilizer, Pesticide, and Agricultural Chemical Industry over
                    five years from April 1992 to April 1997. These data are also broken out by
                    EPA Regions thereby permitting geographical comparisons. A few points
                    evident from the data are listed below.

                           •   About 75 percent of agricultural chemical facility inspections and
                              73 percent of enforcement actions occurred in EPA Regions IV,
                              V, VI, and VII.

             ;              •   Region  IX had the highest  ratio  of enforcement actions to
                              inspections (0.13) and  the  longest  average time  between
                              inspections .(21 months).  This indicates that fewer inspections
                              were conducted in relation to the number of facilities in the
                              Region, but that these inspections were more likely to result in an
                              enforcement action than inspections conducted in other Regions.

                           •   With the exception of Region I, in which no inspections or
                              enforcement actions were carried out in between 1992 and 1997,
                              Region VIII had the lowest enforcement to inspection rate (0.03).
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        Compliance and Enforcement History
Table 25: Five-Year Enforcement and Compliance Summary for the Fertilizer, Pesticide, and
Agricultural Chemical Industry
A
Region
I
II
III
IV
V
VI
VII
vni
IX
X
TOTAL
B
Facilities
in
Search
3
11
18
77
35
34
43
9
25
8
263
c
Facilities
Inspected
0
8
16
44
23
21
31
5
10
6
164
D
Number of
Inspections
0
50
123
449
128
167
225
33
72
46
1,293
E
Average
Months
Between
Inspections
--•
13
9
10
16
12
11
16
21
10
12
F
Facilities with
1 or More
Enforcement
Actions
0
3
2
15
4
5
8
1
5
4
47
G
Total
Enforcement
Actions
0
4
10
41
7
9
17
1
9
4
102
H
Percent
State
Lead
Actions
0%
75%
80%
83%
57%
56%
71%
100%
78%
25%
74%
I
Percent
Federal
Lead
Actions
0%
25%
20%
17%
43%
44%
29%
0%
22%
75%
26%
J
Enforcement
to Inspection
Rate
--
0.08
0.08
0.09
0.05
0.05
0.08
0.03
0.13
0.09
0.08
Source: Data obtained from EPA's Integrated Data for Enforcement Analysis (IDEA) system in 1997.
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       Compliance and Enforcement History
VII.B. Comparison of Enforcement Activity Between Selected Industries

                    Tables 26 and 27 allow the compliance history of the agricultural chemical
                    sector to be compared to the other industries covered by the industry sector
                    notebooks.  Comparisons between Tables 26 and 27 permit the identification
                    of trends in compliance and enforcement records of the various industries by
                    comparing data covering five years (April  1992 to April 1997) to that of the
                    last year for which data were available (April 1996 to April 1997). Some
                    points evident from the data are listed below.

                          °   The agricultural chemical sector was inspected more frequently
                              than most of the sectors shown (12 months on average between
                              inspections).

                          •   Between 1992 and 1997, the industry had a higher enforcement
                              to inspection rate than most sectors (0.08); however, in 1997 the
                              ratio decreased to 0.05 which is lower than most sectors.

                          «   The  agricultural  chemical sector  had  one of  the  highest
                              percentages of facilities inspected with one or more violations (97
                              percent) in 1997, but one of the lowest percentages  of facilities
                              with one or more enforcement  actions (5 percent).

                    Tables 28 and 29 provide a more in-depth comparison between the Fertilizer,,
                    Pesticide, and Agricultural Chemical Industry and other sectors  by breaking
                    out the compliance and enforcement data by environmental statute. As in the
                    previous Tables (Tables 26 and 27), the data cover the years 1992 to 1997
                    (Table 28) and 1997 (Table 29) to facilitate the identification of recent trends.
                    A few points evident from the data are listed below.

                          •   The percent of inspections carried out under each environmental
                              statute has changed only slightly between the average of the years
                              1992  to 1997 and that of the past year.  The Clean  Air  Act
                              accounted  for the most inspections (43 percent)  during  this
                              period. This increased to almost half of all agricultural chemical
                              facility inspections (49 percent) in 1997.

                          •   The   percent  of   enforcement  actions  taken  under each
                              environmental statute changed significantly from the  1992 to
                              1997 period to the past year. Enforcement actions taken under the
                              Clean Air  Act  increased from 39 percent to  55  percent  and
                              enforcement  actions taken under RCRA increased from 30
                              percent to 3 6 percent. At the same time, the enforcement actions
                              taken under the Clean Water Act went from 20 percent in 1992 to
                              1995 to no actions in 1997.
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Agricultural Chemical Industry
       Compliance and Enforcement History





















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Sector Notebook Project
158
September 2000

-------
Agricultural Chemical Industry
       Compliance and Enforcement History





















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160
September 2000

-------
Agricultural Chemical Industry
       Compliance and Enforcement History















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\\ Drv Cleaning
Sector Notebook Project
161
September 2000

-------
Agricultural Chemical Industry
       Compliance and Enforcement History
VII.C. Review of Major Legal Actions

   Major Cases/Supplemental Environmental Projects
                    This section provides summary information about major cases that have
                    affected this sector,  and a list of Supplemental Environmental Projects
                    (SEPs).
   VII.C.l. Review of Major Cases
                    As indicated in EPA's Enforcement Accomplishments Report, FY1995 and
                    FY1996publications, about 17 significant enforcement actions were resolved
                    between  1995 and 1996 for the Fertilizer,  Pesticide, and Agricultural
                    Chemical Industry.

                    American Cyanamid Company On June 28, 1995, Region II issued an
                    administrative complaint  against  American Cyanamid  Company for
                    violations at its Lederle Laboratories facility  located in Pearl River, New
                    York.  The complaint  proposed assessment  of a $272,424 fine for the
                    company's failure to submit timely TRI Form Rs for 1,1,1-trichloroethane,
                    naphthalene, phosphoric acid, toluene, manganese compounds  and zinc
                    compounds for the reporting years 1990, 1991, 1992, and 1993.

                    Precision Generators,  Inc.  The Regional Administrator signed a consent
                    order in the Precision Generators, Inc., a  FIFRA case,  in which the
                    respondent agreed to pay the proposed penalty of $4,000. The administrative
                    complaint cited the respondent's sale and misbranding of its unregistered
                    pesticide product ethylene fluid used to accelerate the ripening of fruits and
                    vegetables. Such a product is a "plant regulator" falling within the definition
                    of "pesticide" in FIFRA.

                    E.C. Geiger, Inc.  On August 18, 1995, the Regional Administrator signed
                    a  consent  agreement  and consent order finalizing settlement  of the
                    administrative proceeding against E.C. Geiger,  Inc.   of Harleysville,
                    Pennsylvania,  for violations  of sections 12(a)(l)(A) and (B) of FIFRA, 7
                    U.S.C. section 136j(a)(l)(A) and (B).  The complaint alleged that during
                    1992, Geiger sold or distributed an unregistered and misbranded pesticide
                    product,  a rooting hormone called "Indole-3-butyric Acid-Horticultural
                    Grade." For these violations the complaint sought a $ 14,000 penalty. Geiger
                    has agreed to pay a penalty of $8,900.

                    Rhpne-Poulenc, Inc. Region III reached a settlement with Rhone-Poulenc,
                    Inc., in a Part II administrative action brought for violations of RCRA boiler
                    and industrial furnace (BIF) regulations at Rhone-PoulenC's Institute, West
                    Virginia plant. The settlement calls for Rhone-Poulenc to pay a penalty of
                    over $244,000 and to undertake numerous compliance tasks.
 Sector Notebook Project
162
September 2000

-------
Agricultural Chemical Industry
       Compliance and Enforcement History
                    IMC-Agrico Company On November 8,1994, the Regional Administrator
                    ratified a consent decree between the United States and IMC-Agrico
                    Company concerning IMC's violations of section 301 (a) of the CWA. IMC
                    owns and operates phosphate rock mines and associated processing facilities
                    in Florida and Louisiana.  Eight of its mineral extraction operations located
                    throughout Florida and its Port Sutton Phosphate Terminal located in Tampa,
                    Florida, were the subject of this referral. The action arose out of IMC's
                    violation of its permit effluent limits for a variety of parameters including
                    dissolved oxygen, suspended solids, ammonia, and phosphorous, as well as
                    non-reporting and stormwater violations at the various facilities-over 1,500
                    permit violations total. The case was initiated following review of the facility
                    discharge monitoring reports and EPA and state inspections of the sites. The
                    consent decree settlement involved an up-front payment of $835,000 and a
                    $265,000 Supplemental  Environmental Project (SEP).  The pollution
                    prevention SEP involved converting IMC's scrubber discharge and intake
                    water systems into a closed loop system, greatly reducing pollution loading
                    at the Port Sutton facility, by April  1995.

                    J.T. Eaton & Company, Inc. J.T. Eaton & Company, Inc. distributed and
                    sold at least 13 unregistered pesticides (mostly  rodenticides).  These
                    unregistered pesticides resulted from varying the form of the rodent bait and
                    the packaging of several of Eaton's  registered products (e.g., registered as a
                    bulk product) but sold in ready-to-use place packs.   The company also
                    distributed and sold a misbranded  pesticide product and made inaccurate
                    claims in advertising for another product. A stop sale, use, or removal order
                    and an administrative complaint were issued simultaneously on March 23,
                    1995.  The penalty assessed in the complaint was $67,500. The complaint
                    was settled on August 25, 1995, for $40,000.

                    Citizens Elevator Co.,  Inc.   Citizens Elevator  Co.  repackaged and
                    distributed and sold the pesticide "Preview" in five gallon buckets, many
                    bearing pie filling labels, to at least 24 customers, constituting the distribution
                    and sale of an unregistered pesticide. The complaint, issued June 30, 1994,
                    assessed a penalty of $108,000. In supplemental environmental projects for
                    the prevention  of spills of pesticides and fertilizers and the safer, more
                    efficient storage and application of pesticides and fertilizer. The respondent
                    spent $184,771. A consent agreement signed June 30,1995, settled the case
                    for $8,400.

                    Nitrogen Products, Inc.  On September 25, 1995, a joint stipulation and
                    order of dismissal was filed in the United States District Court for the Eastern
                    District of Arkansas. Nitrogen Products, Inc.  (NPI), agreed to pay a civil
                    penalty of $243,600 to the United States for violations of the Clean Air Act,
                    and Subparts A and R of 40 CFR Part 61. The foreign parent corporation,
                    Internationale Nederlanden  Bank, N.V.,  acquired the facility  through
Sector Notebook Project
163
September 2000

-------
Agricultural Chemical Industry
       Compliance and Enforcement History
                    foreclosure and expended over $2 million to cover the phosphogypsum stack
                    andregrade.

                    Micro Chemical, Inc. The illegal transportation of hazardous waste by a
                    Louisiana pesticide formulation company,  Micro Chemical,  Inc., to  an
                    unpermitted disposal facility in violation of RCRA resulted in a $500,000
                    fine, five years of probation, and compliance with corrective action measures
                    contained in a corrective action administrative order on consent. In March
                    1990, Micro Chemical transported 100 cubic yards of hazardous waste from
                    its facility to a field in Baskin, Louisiana-a location that did not have a RCRA
                    permit. After its discovery, it was removed under the Louisiana Department
                    of Agriculture's guidance.  Micro Chemical has taken measures to stabilize
                    and prevent the spread of pesticide contamination from the Micro Chemical
                    facility site, as required by a RCRA 3008(h)"corrective action administrative
                    order on consent. The order will result in the removal of all contaminated
                    soil at the site, and the remediation of all off-site contamination that has
                    migrated into a drainage basin located adjacent to the site.

                    Chempace Corporation On September 26, 1996, Region V PTES filed a
                    civil administrative complaint against Chempace corporation of Toledo, Ohio
                    alleging 99 counts for the distribution or sale of unregistered andmisbranded
                    pesticides, and pesticide production in unregistered establishments. The total
                    proposed penalty in the complaint is $200,000. The case is significant in that
                    Chempace had, previous to the complaint, canceled all of the company's
                    pesticide product registrations pursuant to section 4 of FIFRA, as well as their
                    establishment registration  pursuant to section 7.  However, the company
                    continued to produce and sell those canceled pesticides in a facility that was
                    not registered.

                    Northrup King Co.  On September 30, 1996, as a result of a FIFRA
                    inspection conducted by Region V on March 27-28,1996, Region V issued
                    a FIFRA civil complaint to Northrup King Co. of Golden Valley, Minnesota.
                    The pesticide involved in the case is a genetically engineered corn seed that
                    protects against the corn borer.  Because this case  is the first FIFRA
                    complaint involving a genetically engineered pesticide, the case is nationally
                    significant.  The complaint alleged 21  counts of sale and distribution of an
                    unregistered pesticide, 21  counts for failure to  file a Notice of Arrival  for
                    pesticide  imports, and 8  counts  of pesticide  production in unregistered
                    establishments,  for a total  proposed penalty  of $206,500.  A consent
                    agreement and consent order was filed simultaneously with, and in resolution
                    of the complaint.  The respondent agreed to pay  $165,200,  which is  the
                    largest penalty collected by Region V under FIFRA.

                    Micro Chemical.  Micro Chemical is a pesticide formulating, mixing, and
                    packaging facility 3,000 feet up gradient of the Winnsboro's groundwater
                    well complex. In March 1990, a release from the facility was reported by a
                     citizen. Investigations revealed that the company had attempted to dump 100
 ejector Notebook Project
164
-September 2000

-------
Agricultural Chemical Industry
      Compliance and Enforcement History
                    cubic yards of pesticide contaminated soil offsite.  People living near the
                    dump site became ill from the fumes and the state ordered the soil to be
                    returned to Micro Chemical. Ultimately a criminal case was initiated for the
                    midnight dumping. Other storage violations detected were the subject of an
                    administrative complaint issued in September 1992'. A RCRA 3008(h) order
                    on consent was entered into on September 1994 to remediate the site. In
                    resolving the September 1992 complaint, a final order was issued on March
                    28,1996.  Micro Chemical agreed to pay a penalty of $25,000 and agreed to
                    fund a SEP valued at $25,000. The SEP established collection events for
                    household waste and waste pesticides in the Franklin Parish area. During
                    FY96, the SEP enabled about 100 tons of waste to be collected and properly
                    disposed.

                    Terra  Industries, Inc.   At  the  request of the Chemical Emergency
                    Prevention and Preparedness Office (CEPPO), and in accordance with section
                    112(r) of the CAA, EPA released the results of its investigation into the cause
                    of an explosion of the ammonium nitrate plant at this nitrogen  fertilizer
                    manufacturing  facility.  The report released in January 1996 identifies
                    numerous unsafe operating procedures at the plant as contributing factors to
                    the explosion, and recommends certain standard operating procedures which
                    would help prevent similar occurrences at ammonium nitrate production
                    facilities.

                    The Terra explosion occurred on December 13,1994, killing four individuals
                    and injuring 18 others.  It also resulted in the release of approximately 5,700
                    tons of anhydrous ammonia to the air and approximately 25,000 gallons of
                    nitric acid to the ground and required evacuation over a two-state area of over
                    2,500 persons from their homes.

                    In a subsequent action, an administrative civil complaint alleging violations
                    of EPCRA sections 213 and 313, and section 8(a) of TSCA, was filed citing
                    that Terra International failed to submit Toxic Release Inventory (TRI)
                    information to EPA in a timely manner, and data submitted to EPA by Terra
                    failed to include releases of more than 17 million pounds of toxic chemicals
                    to the environment on-site.

                     Pfizer/AgrEvo Reporting of unreasonable adverse effects information is
                     required under FIFRA section 6(a)(2), and failure to submit such reports has
                     resulted in a $192,000 settlement involving AgrEvo Environmental Health,
                     Inc. and Pfizer, Inc. The case arose in early 1994  after an individual reported
                     disabling neurological symptoms and chemical  sensitivity after using RID
                     products  to kill lice.   The ensuing EPA investigation revealed numerous
                     additional unreported incidents involving RID which is manufactured by
                     AgrEvo and distributed by Pfizer. EPA amended the complaint charging 24
                     counts against each company.  FIFRA 6(a)(2) requires pesticide registrants
                     to submit to EPA any additional information (beyond that submitted in the
                     pesticide registration process) that they have regarding unreasonable adverse
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 Agricultural Chemical Industry
        Compliance and Enforcement History
                     effects of their pesticides on human health or the environment.   The
                     information is used by the Agency in-the determination of risks associated
                     with pesticides.

                     Rohm and Haas Company This complaint cited Rohm and Haas for 66
                     violations under FIFRA section 12(a)(l)(c), for the distribution or sale of a
                     registered pesticide the composition of which differed from the composition
                     as  described in its registration under FIFRA section 3.   EPA registers
                     pesticides based upon the accurate assessment of components used in the
                     manufacture  of the product.  Use of an unapproved formula can lead to
                     production of  a pesticide for which no  assessment of risk has been
                     determined or result in unknown  synergistic effects. Following settlement
                     negotiations, and in accordance  with the FIFRA Enforcement Response
                     Policy, the original penalty of $330,000 was reduced to $118,800, based on
                     a 20% reduction to the gravity level, a 40% reduction for immediate self-
                     disclosure, mitigation, and corrective actions, and a 15% reduction for good
                     attitude, cooperation, and efforts to comply with FIFRA.
VII.C.2. Supplementary Environmental Projects (SEPs)
                     SEPs are compliance agreements that reduce a facility's non-compliance
                     penalty in return for an environmental project that exceeds the value of the
                     reduction. Often, these projects fund pollution prevention activities that can
                     reduce the future pollutant loadings of a facility. Information on SEP cases
                     can be accessed via the Internet at http ://es.epa.gov/oeca/sep.
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Agricultural Chemicallndustry
          Activities and Initiatives
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

                    This section highlights the activities undertaken by this industry sector and
                    public  agencies  to voluntarily  improve  the  sector's  environmental
                    performance. These activities include  those  initiated independently by
                    industrial trade associations. In this section, the notebook also contains a
                    listing and description of national and regional trade associations.

VIII.A. Sector-Related Environmental Programs and Activities

   National Agricultural Compliance Assistance Center (Ag Center)

                    EPA's Office of Compliance, with the support from the United States
                    Department of Agriculture (USD A), developed EPA's National Agriculture
                    Compliance  Assistance  Center (Ag  Center).  The Ag  Center offers
                    comprehensive,  easy-to-understand  information  about  approaches to
                    compliance that are both environmentally protective and agriculturally sound.

                    The Ag Center  focuses on providing information about EPA's  own
                    requirements. In doing so, the center relies heavily on existing sources of
                    agricultural information and established distribution channels. Educational
                    and technical information on agricultural production is provided by the
                    USDA and other agencies, but assistance in complying with environmental
                    requirements has not traditionally been as readily available. The Ag Center
                    is currently working with USDA and other federal and state agencies to
                    provide the agricultural community, including regional and state regulatory
                    agencies, with a definitive source for  federal environmental compliance
                    information. The Ag Center offers  information on a variety of topics,
                    including the following:

                           •   Pesticides
                           •   Animal waste management
                           •   Emergency planning and response
                           •   Groundwater and surface water
                           •   Tanks / containment
                           •   Solid / hazardous waste

                    Through a toll-free telephone number and a website that is regularly updated
                    and expanded, the Ag Center offers a variety of resources including:

                            •   current  news, compliance policies  and  guidelines,  pollution
                               prevention information, sources  of additional information and
                               expertise, and  summaries of regulatory   initiatives   and
                               requirements

                            •   user-friendly  materials that consolidate  information  about
                               compliance requirements, pollution  prevention,  and  technical
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Agricultural Chemical Industry
                     Activities and Initiatives
                               assistance resources for use by regional and state assistance and
                               educational programs, trade associations, businesses, citizens, and
                               local governments

                            •   agriculture-related information on reducing pollution and using
                               the latest pollution prevention methods and technologies

                            •   information on ways to reduce the costs of meeting environmental
                               requirements, including identification of barriers to compliance

                     The Ag Center's toll-free number is 1-888-663-2155 and the website address
                     is: http://es.epa.gov/oeca/ag/

       National Pesticide Information Retrieval System (NPIRS)

                     Purdue University has developed a collection of databases through their
                     Center for Environmental and Regulatory Information Systems, one of which
                     is the National Pesticide Information Retrieval System. NPIRS is a collection
                     of six databases related to pesticides, including product registration document
                     information, data submitter information, residue tolerances, fact sheets,
                     material safety data sheets, and the daily federal register. Full search access
                     to the NPIRS databases is by annual subscription.

       Association of American Plant Food Control Officials (AAPFCO) Label Recommendations

                     The AAPFCO is considering a set of recommendations issued by a task force
                     of fertilizer producers and state officials. These recommendations call for
                     labeling and standards for non-nutrient constituents in fertilizer and directions
                     that will allow users to apply fertilizers at a rate that will not exceed these
                     standards.  One proposed addition to labels is to list all raw materials,
                     including recycled wastes; however, the concentration of these materials will
                     not be required (ARA, 1997).

       Agricultural Research Institute

                     ARI was  founded in 1951 as a  part of the National Academy of Sciences,
                     then incorporated separately in 1973. ARI analyzes agricultural problems and
                     promotes research by its members to solve them. ARI publishes annual
                     meeting minutes, a directory, books, pamphlets, and newsletters.

       National Association of State Departments of Agriculture (NASDA)

                     NASD A was founded in 1916 by directors of state and territorial departments
                     of agriculture to coordinate policies, procedures, laws, and activities between
                     the .states and federal agencies and Congress. NASDA conducts research,
                     holds  a trade show, and distributes several bulletins, newsletters, and
                     directories.
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Agricultural Chemical Industry
                    Activities and Initiatives
       ChemAlliance
                    EPA's Office of Compliance developed ChemAlliance, a new Compliance
                    Assistance Center for the chemical industry. Among its features is an exciting
                    "expert help," which offers an interactive guide to finding compliance
                    resources specific to a user's needs. Take a "virtual plant tour" to find out
                    which regulations apply to your company's  operations by clicking on a
                    detailed chemical  plant illustration. ChemAlliance can  be reached at
                    1-800-672-6048; its web site is located at. http://www.chemalliance.org,
VHI.B. EPA Voluntary Programs

       Pesticide Environmental Stewardship Program (PESP)
                    The Pesticide Environmental Stewardship Program (PESP) is a broad effort
                    by  EPA, USD A, and the FDA to reduce pesticide use and risk in both
                    agriculture and  nonagricultural settings.  In September 1993,  the three
                    agencies announced a federal commitment to two major goals: 1) developing
                    specific use/risk reduction  strategies that include reliance on biological
                    pesticides and other approaches to pest control that are thought to be safer
                    than traditional chemical methods, and 2) by the year 2000, having 75 percent
                    of United States agricultural  acreage adopt integrated pest management
                    programs.

                    A key part of the PESP is the public/private partnership which began when
                    EPA, USD A, and FDA announced the partnership and more than 20 private
                    organizations signed  on as charter members. All organizations with a
                    commitment to pesticide use/risk reduction are eligible to join the  PESP,
                    either as  Partners or Supporters. The PESP program  has -35  partners.
                    Together, these partners represent at least 45,000 pesticide users.  The
                    program has a goal of adding 35 new partners per year.
       33/50 Program
              The 33/50 Program is a ground breaking program that has focused on reducing
              pollution from seventeen high-priority chemicals through voluntary partnerships with
              industry. The program's name stems from its goals:  a 33% reduction in toxic
              releases by 1992, and a 50% reduction by 1995, against a baseline of 1.5 billion
              pounds of releases and transfers in 1988. The results have been impressive: 1,300
              companies have joined the 33/50 Program (representing over 6,000 facilities) and
              have reached the national targets a year ahead of schedule.  The 33% goal was
              reached in 1991, and the 50% goal ~ a reduction of 745 million pounds of toxic
              wastes — was reached in 1994. The 33/50 Program can provide case studies on many
              of the corporate accomplishments in reducing waste (Contact 33/50 Program Director
              David Sarokin--202-260-6396).

              Table 30 lists those companies participating in the 33/50 program that reported the
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                     Activities and Initiatives
              SIC codes 2873,2874,2875, and 2879 to TRI.  Some of the companies shown also
              listed facilities  that are not producing agricultural chemicals.  The number of
              facilities within each company that are participating in the 33/50 program and that
              report SIC codes  2873, 2874, 2875, and 2879 is  shown.  Where available and
              quantifiable against 1988 releases and  transfers, each company's 33/50 goals for
              1995 and the actual total releases and transfers and percent reduction between 1988
              and 1995 are presented.  Eleven of the seventeen target chemicals were reported to
              TRI by agricultural chemical facilities in 1995.

              Table 30 shows that 24 companies comprised of 78 facilities reporting SIC 287
              participated in the 33/50 program. For those companies shown with more than one
              agricultural chemical facility, all facilities may not have participated in 33/50. The
              33/50 goals shown for companies with multiple facilities, however, were company-
              wide, potentially aggregating more than one facility and facilities not carrying out
              agricultural chemical operations.  In addition to company-wide goals,  individual
              facilities within a company may have had their  own 33/50 goals or may have been
              specifically listed as not participating in the 33/50 program. Since the actual percent
              reductions shown in the last column apply to only the companies' agricultural
              chemical facilities, direct comparisons to those company goals incorporating non-
              agricultural chemical facilities or excluding certain facilities may not be possible.
              For information on specific facilities participating in 33/50, contact David Sarokin
              (202-260-6907) at the 33/50 Program Office.
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Agricultural Chemical Industry
                   Activities and Initiatives
Table 30: Fertilizer, Pesticide, and Agricultural Chemical Industry Participation in the 33/50
Program
Parent Company
(Headquarters Location)
AMERICAN HOME PRODUCTS CORP.
MADISON, NJ
ARCADIAN CORP.
MEMPHIS, TN
BAY ZINC CO. INC.
MOXEE CITY, WA
CHEM-TECH LTD.
DBS MOINES, IA
CHEVRON CORP.
SAN FRANCISCO, CA
CONAGRA INC.
OMAHA, NE
E.I. DU PONT DE NEMOURS & CO
WILMINGTON, DE
ELF AQUITAINE INC.
NEW YORK, NY
FIRST MISSISSIPPI CORP.
JACKSON, MS
FMC CORPORATION
CHICAGO, IL
GLAXO WELLCOME INC.
RESEARCH TRIANGLE PARK, NC
GOWAN COMPANY
YUMA,AZ
IMC FERTILIZER GROUP INC.
NORTHBROOK, IL
ISK AMERICAS INC.
ATLANTA, GA
LAROCHE HOLDINGS INC.
ATLANTA, GA
MALLINCKRODT GROUP INC.
SAINT LOUIS, MO
MILES INC.
PITTSBURGH, PA
MONSANTO COMPANY
SAINT LOUIS, MO
RHONE-POULENC INC.
MONMOUTH JUNCTION, NJ
SC JOHNSON & SON INC.
RACINE, WI
SANDOZ CORPORATION
NEW YORK, NY
TALLEY INDUSTRIES
PHOENIX, AZ
UNIVERSAL COOPERATIVES INC.
MINNEAPOLIS, MN
UNOCAL CORPORATION
LOS ANGELES, CA
Total
Company-Owned
Facilities Reporting
33/50 Chemicals
2
6
1
1
3
6
2
1
7
5
1
1
7
2
1
1
1
1
.21
1
3
1
1
2
78
Company- Wide
% Reduction
Goal1
(1988 to 1995)
49
0
50
90
50
8
50
49
0
50
37
0
0
50
0
44
38
23
50
50
50
0
70
50
...
1988 TRI Releases
and Transfers of
33/50 Chemicals
(pounds)2
47,950
4,340
77,250
800
8,746
17,086
144,412
3,068
70.1,144
6,190
1,125
0
56,350
884,412
17,590
0
39,822
0
3,128,263
19,086
207,086
8,243
17,750
0
5,390,713
1995 TRI Releases
and Transfers of
33/50 Chemicals
(pounds)2
73,876
10,127
252
0
0
5,238
440,370
0
214,334
2,339
0
2,207
51,548
726,713
0
0
6,650
1,260
1,392,117
20,096
87,000
2,289
1,265
9
3,037,690
% of Change
per Facility
(1988-1995)
-54
-133
100
100
100
69
-205
100
69
62
100
—
9
18
100
.
83

55
-5
58
72
93
—
44
Source: United States EPA 33/50 Program Office, 1997.
' Company-Wide Reduction Goals aggregate all company-owned facilities which may include facilities not producing agricultural chemicals.
2 Releases and Transfers are ftom facilities only. 1995 33/50 TRI data were not available at time of publication.
* = Reduction goal not quantifiable against 1988 TRI data. ** = Use reduction goal only. *** = No numeric reduction goal.
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       Project XL

             Project XL was initiated in March 1995 as a part of President Clinton's Reinventing
             Environmental Regulation initiative.  The projects seek to achieve cost effective
             environmental  benefits by providing participants  regulatory flexibility on the
             condition that they produce greater environmental benefits.  EPA and program
             participants will negotiate and sign a Final Project  Agreement, detailing specific
             environmental objectives that the regulated entity shall satisfy.  EPA will provide
             regulatory flexibility as an incentive for the participants'  superior environmental
             performance.  Participants are encouraged to seek stakeholder support from local
             governments, businesses, and environmental groups.

                    There have been at least two Project XL proposals relating to fertilizer
                    production, however both of these have been either rejected or withdrawn.
                    PCS Nitrogen (formerly Arcadian Fertilizer) had proposed to reuse stockpiled
                    phosphogypsum as an ingredient in a soil enhancer.  Another proposal by
          '          Dow Chemical Company in Louisiana was to trade off equipment leak
                    reductions for relief from some emissions control, monitoring, reporting and
                    record-keeping requirements.

                    EPA hopes to implement fifty pilot projects in four categories, including
                    industrial facilities, communities, and government facilities regulated by
                    EPA.  Applications will be accepted  on a  rolling basis. For  additional
                    information regarding XL projects, including application procedures and
                    criteria, see the May 23, 1995 Federal Register Notice. (Contact: Fax-on-
                    Demand Hotline 202-260-8590, Web: http://www.epa.gov/ProjectXL, or
                    Christopher Knopes at EPA's Office of Policy, Planning and Evaluation 202-
                    260-9298)

       Climate Wise Program

             EPA's ENERGY STAR Buildings Program is a voluntary, profit-based program
             designed to improve the energy-efficiency in commercial and industrial buildings.
             Expanding the successful Green Lights Program, ENERGY  STAR Buildings was
             launched in 1995. This program relies on a 5-stage strategy designed to maximize
             energy savings thereby lowering energy bills, improving occupant comfort, and
             preventing pollution — all at the same time. If implemented in every commercial and
             industrial building in the United States, ENERGY STAR Buildings could cut the
             nation's energy bill by up to $25 billion and prevent up to 35% of carbon dioxide
             emissions. (This is equivalent to taking 60 million cars of the road). ENERGY STAR
             Buildings participants include corporations; small and medium sized businesses;
             local, federal and state governments; non-profit groups; schools; universities; and
             health care facilities. EPA provides technical and non-technical support including
             software, workshops, manuals, communication tools, and an information hotline.
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                     Activities and Initiatives
             EPA's Office of Air and Radiation manages the operation of the ENERGY STAR
             Buildings Program. (Contact: Green Light/Energy Star Hotline at 1 -888-STAR-YES
             or Maria Tikoff Vargas, EPA Program Director at 202-23 3 -9178 or visit the ENERGY
             STAR Buildings Program website at http://www.epa.gov/appdstar/buildings/)

       Green Lights Program

             EPA's Green Lights program was initiated in 1991 and has the goal of preventing
             pollution by encouraging United States institutions to use energy-efficient lighting
             technologies. The program saves money for businesses and organizations and creates
             a cleaner environment by reducing pollutants released into the atmosphere. The
             program has over 2,345 participants which include major corporations, small and
             medium sized businesses, federal, state and local governments, non-profit groups,
             schools, universities, and health care facilities. Each participant is required to survey
             their facilities and upgrade lighting wherever it is profitable.  As of March 1997,
             participants had lowered their electric bills by $289 million annually. EPA provides
             technical assistance to the participants through a decision support software package,
             workshops and manuals, and an information hotline.  EPA's Office of Air and
             Radiation is responsible for operating the Green Lights Program.  (Contact: Green
             Light/Energy Star Hotline at 1 -888-STARYES or Maria Tikoff Vargar, EPA Program
           -- Director, at 202-233-9178)

       WasteWi$e Program

             The WasteWi$e Program was started in 1994 by EPA's Office of Solid Waste and
             Emergency Response. The program is aimed at reducing municipal solid wastes by
             promoting waste prevention, recycling collection and the manufacturing and purchase
             of recycled products.  As of 1997,  the program had about 500 companies as
             members, one third of whom are Fortune 1000 corporations.  Members agree to
             identify and implement actions to reduce their solid wastes setting waste reduction
             goals and providing EPA with yearly progress reports. To member companies, EPA,
             in turn, provides technical assistance, publications, networking opportunities, and
             national and regional recognition. (Contact: WasteWi$e Hotline at 1-800-372-9473
             or Joanne Oxley, EPA Program Manager, 703-308-0199)
       NICE3
              The United States Department of Energy is administering a grant program called The
              National Industrial Competitiveness through Energy, Environment, and Economics
              (NICE3).  By providing grants of up to 45 percent of the total project cost, the
              program encourages industry to reduce industrial waste at its source and become
              more energy-efficient and cost-competitive through waste minimization efforts.
              Grants are used by industry to design, test, and demonstrate new processes and/or
              equipment with the potential to reduce pollution and increase energy efficiency. The
              program is open to  all industries; however,  priority is given to proposals from
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           Activities and Initiatives
             participants in the forest products, chemicals, petroleum refining, steel, aluminum,
             metal   casting   and   glass   manufacturing  sectors.  (Contact:
             http//www.oit.doe.gov/access/ niceS, Chris Sifri, DOE, 303-275-4723 or Eric Hass,
             DOE, 303-275-4728)

       Design for the Environment (DfE)

             DfE is working with several industries to identify cost-effective pollution prevention
             strategies that reduce risks to workers and the environment.  DfE helps businesses
             compare and evaluate the performance,  cost, pollution prevention benefits, and
             human health and environmental risks associated with existing and alternative
             technologies.  The goal of these projects is to encourage businesses to consider and
             use cleaner products, processes, and technologies.  For more information about the
             DfE Program, call (202) 260-1678. To obtain copies of DfE materials or for general
             information  about  DfE,  contact  EPA's  Pollution  Prevention  Information
             Clearinghouse at (202) 260-1023 or visit the DfE Website at http://es.inel.gov/dfe.
VIII.C. Trade Association/Industry Sponsored Activity

       Vin.C.l.  State Advisory Groups

                    Association of American Pesticide Control Officials (AAPCO)
                    P.O. Box 1249                               Members: 55
                    Hardwick, VT 05843                         Staff: 1
                    Phone: 802-472-6956
                    Fax: 802-472-6957
                    E-mail: aapco@plainfield.bypass.com

                    Formed in 1947, the Association of American Pesticide Control Officials
                    (AAPCO) consists of state and federal pesticide regulatory officials.  All
                    federal and provincial Canadian officials, officials of all North American
                    countries involved with the regulation of pesticides may be members of
                    AAPCO as well.  AAPCO holds meetings twice a year and publishes an
                    annual handbook  that contains  uniform policies and model  pesticide
                    legislation that the association has adopted.

                    AAPCO aims to promote uniform and effective state legislation and pesticide
                    regulatory programs.  Its other  objectives  are to  develop   inspection
                    procedures,  to promote labeling and safe use of pesticides, to provide
                    opportunities for  members  to exchange information, and  to work with
                    industry to  promote the usefulness and effectiveness of pesticide products.
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           Activities and Initiatives
                    State FIFRA Issues Research and Evaluation Group (SFIREG)
                    P.O. Box 1249                              Members:
                    Hardwick, VT 05843                         10 state representatives
                    Phone: 802-472-6956
                    Fax: 802-472-6957
                    E-mail: aapco@plainfield.bypass.com

                    The State FIFRA Issues Research and Evaluation Group evolved in 1978 out
                    of a cooperative agreement between the EPA's Office of Pesticide Programs
                    (OPP)  and the Association of American Pesticide Control Officials
                    (AAPCO).  SFIREG is an independent but related body of AAPCO that
                    provides state comments to the Office of Pesticide  Programs on issues
                    relating to the manufacture, use and disposal of pesticides.  Its membership
                    is comprised often state representatives, who represent and are selected by
                    the states in each of the ten EPA Regions.
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       VIII.C.2.  Trade Associations
                    Association of American Plant Food Control Officials (AAPFCO)
                    University of Kentucky               Members: 200
                    Division of Regulatory Services
                    103 Regional Services Building
                    Lexington, KY 40546-0275
                    Phone: 606-257-2668
                           606-257-2970
                    Fax:   606-257-7351

                    The AAPFCO is an organization of state fertilizer control officials from the
                    United States and Canada who are involved in the administration of fertilizer
                    regulations and laws.  The AAPFCO's purpose is to achieve uniformity
                    throughout their membership with regards to promoting effective legislation,
                    adequate sampling, accurate labeling, and safe use of fertilizers, as well as to
                    study and discuss relevant issues.
                    Agricultural Retailers Association (ARA)
                    11701 BormanDr., Ste. 110        Members: 1,100
                    St. Louis, MO 63146              Staff: 17
                    Phone:800-844-4900
                    Fax:314-567-6808

                    The Agricultural Retailers Association was founded in 1954 and is made up
                    of dealers, manufacturers, and suppliers of fluid fertilizers and agrichemicals,
                    as well as equipment manufacturers, retail affiliations, and state association
                    affiliates. ARA was formerly known as  the National Nitrogen Solutions
                    Association.  Their publications include Agricultural Retailers Association-
                    Membership  Directory  and Buyer's  Guide  (annual),  Connections, a
                    bimonthly newsletter, and the Fluid Fertilizer Manual.
                     Fertilizer Industry Round Table (FIRT)
                     5234 Glen Arm Rd.               Nonmembership
                     Glen Arm, MD 21057
                     Phone: 410-592-6271
                     Fax:410-592-5796

                     The Fertilizer Industry Round Table was founded in 1951.  Participants
                     include  production, technical,  and research personnel  in the fertilizer
                     industry. FIRT acts as a forum for discussion of technical and production
                     problems. They hold an annual meeting and publish the proceedings.
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                     Activities and Initiatives
                    The Fertilizer Institute (TFI)
                    5012nd St., NE
                    Washington, DC 20002
                    Phone:202-675-8250
                    Fax: 202-544-8123
           Members: 300
           Staff: 22
                    The Fertilizer Institute was founded in 1970 and now has 48 affiliated groups.
                    Members include producers, manufacturers,  retailers, trading firms, and
                    equipment manufacturers. TFI represents members in various legislative,
                    educational, and technical areas, and provides information and public
                    relations programs. Publications include: Directory of Fertilizer References,
                    annual; Fertilizer Facts and Figures, annual; Fertilizer Institute-Action
                    Letter, monthly; Fertilizer Record, periodic.
                    Chemical Manufacturers Association (CMA)
                    1300 Wilson Blvd.                Members: 185
                    Arlington, VA 22209              Staff: 280
                    Phone: 703-741-5000
                    Fax: 703-741-6000

                    The Chemical Manufacturers Association was founded in 1872 and now has
                    a budget of $36 million.  CMA conducts advocacy and administers research
                    areas of broad  import  to  chemical manufacturing, such as  pollution
                    prevention and other  special research programs.   CMA also conducts
                    committee studies, operates the Chemical Emergency Center (CHEMTREC)
                    for guidance to  emergency service on handling emergencies  involving
                    chemicals and the Chemical Reference Center which offers health and safety
                    information  about chemicals to the public.  Publications include semi-
                    monthly newsletters, ChemEcology and CMA News, and the CMA Directory
                    and User's Guide.
                    Chemical Specialties Manufacturers Association (CSMA)
                    1913 Eye St., NW                 Members: 425
                    Washington, DC 20006            Staff: 31
                    Phone:202-872-8110
                    Fax:202-872-8114

                    The Chemical Specialties Manufacturers Association was founded in 1914
                    and is made up of manufacturers, marketers, formulators, and suppliers of
                    household, industrial, and personal care chemical specialty products such as
                    pesticides, cleaning products, disinfectants, sanitizers, and polishes. CSMA
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                    serves as a liaison to federal and state agencies and public representatives,
                    provides information and sponsors seminars on governmental activities and
                    scientific developments.
                    American Crop Protection Association (ACPA)
                    1156 15th St., NW, Ste. 400        Members: 82
                    Washington, DC 20005            Staff: 29
                    Phone: 202-296-1585
                    Fax: 202-463-0474

                    The American Crop Protection Association was founded in 1933 andnowhas
                    a budget of $7 million. Members include companies involved in producing
                    or  formulating agricultural  chemical  products  including  agricultural
                    fumigants, agricultural scalicides, chemical plant sprays and dusts, defoliants,
                    soil disinfectants, weed killers, and others. It is comprised of legislative,
                    regulatory and science  departments and publishes  a periodic bulletin,
                    manuals, Growing Possibilities, quarterly, and This Week and Next, weekly.
                    Western Crop Protection Association (WCPA)
                    3835 N. Freeway Blvd. Ste. 140    Members: 170
                    Sacramento, CA 95834            Staff: 6
                    Phone:  916-568-3660
                    Fax:916-565-0113

                    The WCPA  is  a  regional organization of manufacturers, formulators,
                    distributors, and dealers of basic pesticide chemicals and suppliers of
                    solvents, diluents, emulsifiers, and containers. They are affiliated with the
                    American Crop Protection Association.  They publish several bulletins and
                    periodicals.
                     National Pest Control Association (NPCA)
                     8100 Oak St.                     Members: 2,300
                     Dunn Loring, VA 22027          Staff: 21
                     Phone:703-573-8330
                     Fax:703-573-4116

                     The National Pest Control Association was founded in 1933 and now has a
                     budget of $2.8 million.  Members include companies engaged in control of
                     insects, rodents, birds, and other pests. NPCA provides advisory services on
                    'control procedures, new products, and safety and business administration
                     practices.   NPCA sponsors research at several universities,  furnishes,
                     technical information and advice to standards and code writing groups, and
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                      Activities and Initiatives
                     maintains an extensive library on pests.  NPCA  publishes many titles
                     including manuals, newsletters, membership guides, technical releases, and
                     reports.
                     International Fertilizer Development Center (IFDC)
                     PO Box 2040                    Nonmembership
                     Muscle Shoals, AL 35662         Staff: 180
                     Phone: 205-381-6600
                     Fax: 205-381-7408

                     The International Fertilizer Development Center was founded in 1974 and
                     includes participants such as scientists, engineers, economists and specialists
                     in market research and development and communications. IFDC uses a $ 13.5
                     million budget to try to alleviate world hunger by increasing agricultural
                     production in the tropics and subtropics through development of improved
                     fertilizers.  IFDC sponsors and conducts studies in fertilizer efficiencies and
                     offers  courses  on fertilizer production,  environmental  issues, and crop
                     sustainability.  They maintain greenhouses and laboratories, and publish
                     several periodicals and manuals.
                    United Products Formulators and Distributors Association(UPFDA)
                    1 Executive Concourse No. 103     Members: 102
                    Duluth,GA 30136                Staff:!
                    Phone: 404-623-8721
                    Fax: 404-623-1714

                    The United Products Formulators and Distributors Association was founded
                    in 1968 and is made up of companies engaged in formulating and distributing
                    pesticide products.  The UPFDA works  to solve problems of member
                    companies and promote sound and beneficial legislation and to cooperate
                    with allied industries.
                    North American Horticultural Supply Association (NAHSA)
                    1790 Arch St.                    Members: 135
                    Philadelphia, PA 19103           Staff: 3
                    Phone: 215-564-3484
                    Fax: 215-564-2175

                    The North American Horticultural Supply Association was founded in 1988
                    and represents horticultural supplies such as greenhouse building materials
                    and supplies, pesticides, and fertilizers. The NAHSA works to strengthen
                    and enhance the relationship between manufacturers and distributors and
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Agricultural Chemical Industry
                                                               Activities and Initiatives
                    promotes distribution in the market.  They publish a quarterly newsletter,
                    NAHSA News, and an annual Industry Calendar.
                    American Agricultural Economics Association (AAEA)
                    1110 Buckeye Ave.               Members: 4,500
                    Ames, IA 50010-8063             Staff: 6
                    Phone:515-233-3202
                    Fax:515-233-3101

                    The American Agricultural Economics Association, founded in 1910, is a
                    professional society of state, federal, and industrial agricultural economists,
                    teachers, and extension workers. The AAEA works to further knowledge of
                    agricultural economics through scientific research, instruction, publications,
                    meetings, and other activities. They publish a bimonthly newsletter, a semi-
                    bimonthly American Journal  of Agricultural  Economics, a  quarterly
                    magazine Choices, and a biennial Handbook Directory.
                     Institute for Agriculture and Trade Policy (LATP)
                     1313 5th St., SE, No. 303
                     Minneapolis, MN 55414
                     Phone:612-379-5980
                     Fax: 612-379-5982

                     The IATP was founded in 1986 and has an annual budget of $1.15 million.
                     They maintain a speakers bureau and conduct research programs on trade
                     agriculture, global institutions, North-South relations, and the Third World.
                     They publish several periodical bulletins.
                     California Fertilizers Association (CFA)
                     17001 St., Ste. 130
                     Sacramento, CA 95814
                     Phone: 916-441-1584
                     Fax: 916-441-2569

                     The CFA represents fertilizer manufacturers, distributors, wholesalers, and
                     retail dealers that sell products within California. They maintain a legislative
                     hotline and publish studies and handbooks on issues pertaining to fertilizers.
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AsricTiVturaV Chemical Industry
                    Activities and Initiatives
                    American Society of Agronomy (ASA)
                    677 S. Segoe Rd.
                    Madison, WI 53711
                    Phone: 608-273-8080
                    Fax: (608) 273-2021
             Members: 12,500
             Staff: 30
                    The ASA was founded in 1907 and presently operates on a budget of 2.5
                    million dollars per year. ASA is a professional society of plant breeders, soil
                    scientists, chemists, educators, technicians, and other concerned with crop
                    production and soil management. ASA sponsors fellowship programs and
                    provides placement service. ASA publishes annual, bimonthly, and monthly
                    periodicals as well as special publications.
                    Potash and Phosphate Institute (PPI)
                    655 Engineering Drive No. 110
                    Norcrdss, GA 30092
                    Phone: 770-447-0335
                    Fax: 770-448-0439
              Members: 14
              Staff: 30
                    PPI supports scientific research in the areas of soil fertility, soil testing, plant
                    analysis, and tissue testing. PPI participates in farmers meetings, workshops,
                    and training courses and publish a quarterly magazine, Better Crops -with
                    Plant Food.
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                  Activities and Initiatives
                  THIS PAGE WAS INTENTIONALLY LEFT BLANK
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Agricultural Chemical Industry
                     Contacts and References
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS
For further information on selected topics within the Fertilizer, Pesticide, and Agricultural Chemical
Industry, a list of contacts and publications are provided below.
Contacts6
Name
Michelle C. Yaras
Arty Williams
Jean Frane
Paul Parsons
David Stangel
Joseph Hogue
Robert McNally
Joseph Nevola
Ellen Kramer
Carol Peterson
Robert A. Forrest
Nancy Fitz
Cathleen Barnes
John MacDonald
Kevin Keaney
Organization
EPA, Office of Enforcement and
Compliance Assurance (OECA),
Agriculture and Ecosystems Division,
Agriculture Branch
EPA, Office of Prevention, Pesticides
and Toxic Substances (OPPT)
EPA, OPPT
EPA, OPPT
EPA, OECA
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
Telephone
202 564-4153
703 305-5239
703 305-5944
703 308-9073
202564-4162
703 308-9072
703 308-8085
703 308-8037
703 305-6475
703 305-6598
703 308-9376
703 305-7385
703 305-7101
703 305-7370
703305-5557 .
Subject
Notebook Contact
Ground Water Pesticide
Management Plan Rule
Food Quality Protection Act
FIFRA Data Requirements
Stored or Suspended
Pesticides; Good Laboratory
Practice Standards; Pesticide
Management and Disposal
FIFRA
Restricted Use
Classifications
FIFRA Pesticide Tolerances
FIFRA Pesticide Tolerances
FIFRA Pesticide Tolerances
FIFRA Tolerance Fee
Structure
FIFRA Exemptions
FIFRA Pesticide
Management and Disposal -
FIFRA Prior Informed
Consent
Certification and Training
FIFRA Worker Protection
Standards
 The following people received a draft copy of this Sector Notebook and  may have provided
 6 Many of the contacts listed above have provided valuable information and comments during the development of
 this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily
 endorse all statements made within this notebook.
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Agricultural Chemical Industry
                    Contacts and References
comments.
Name
Paul Bangser
Philip J. Ross
Don Olson, Chief
Jon Jacobs
Jerry Stubbs
Anne E. Lindsay,
Director
Marcia E. Mulkey,
Director
Artie Williams,
Chief
Seth Heminway
Sam Silverman
Laura Livingston
Samantha Fairchild
Sherri Fields
Tinka Hyde
Robert Lawrence
Diane Callier
Mike Gaydosh
Jo-Ann Semones
Ron Kreizenbeck
Edward M. White
Organization
EPA, Office of General Counsel, Water Division
EPA, Office of General Counsel, Pesticides and Toxic
Substances Division
EPA, Industrial Branch, OECA, Office of Regulatory
Enforcement, Water Enforcement -Division
EPA, OECA, Office of Regulatory Enforcement, Case
Development,, Policy and Enforcement Branch -Eastern
Regions, Toxics and Pesticides Enforcement Division
EPA, Case Development, Policy and Enforcement Branch-
Western Regions, Toxics and Pesticides Enforcement
Division, Office of Regulatory Enforcement
EPA, Field and External Affairs Division
Office of Pesticide Programs
EPA, Office of Pesticide Programs
EPA, Environmental Field Branch, Field and External
Affairs Division, Office of Pesticide Programs
EPA, OC Sector Notebook Coordinator
EPA, Enforcement Coordinator
Region 1
EPA, Enforcement Coordinator
Region 2
EPA, Enforcement Coordinator
Region 3
EPA, Enforcement Coordinator
Region 4
EPA, EPA, Enforcement Coordinator
Region 5
EPA, Enforcement Coordinator
Region 6
EPA, Enforcement Coordinator
Region 7
EPA, Enforcement Coordinator
Region 8
EPA, Enforcement Coordinator
Region 9
EPA, Enforcement Coordinator
Region 10
Assistant Pesticide Administrator, Indiana State Chemist
Office, Purdue University
Telephone
202 260-7630
202 260-0779
202 564-5558
202 564-4037
202 564-4178
703 305-5265
703 305-7090
703 305-5239
202 564-7017
617 565-3443
212 637-4059
215 814-5710
404 562-9684
312886-9296
214 665-6580
913 551-7459
303312-6773
415 744-1547
206 553-1265
765 494-1587
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Agricultural Chemical Industry
                    Contacts and References
Dale Dubberly, Chief
Robin Rosenbaum
Buzz Vance
Donnie Dippel
Paul Kindinger
Joel Padmore
Renee Pinel
Mark Muller
Rick Kirchhoff
Robert Rosenberg
Robert E. Roberts
Diane Bateman
Jay Vroom
Bureau of Compliance Monitoring
Florida Department of Agriculture & Consumer Services
Pesticide Registration Manager, Pesticide & Plant Pest
Management Division, Michigan Department of
Agriculture
Nebraska Department of Agriculture
Assistant Commissioner, Pesticide Programs, Texas
Department of Agriculture
Agricultural Retailers Association (ARA)
Association of American Plant Food Control Officials
(AAPFCO), Food & Drug Protection Division
North Carolina Department of Agriculture
California Fertilizers Association
Institute for Agriculture and Trade Policy
National Association of State Departments of Agriculture
(NASDA)
National Pest Control Association
Executive Director
Environmental Council of States (ECOS)
The Fertilizer Institute (TFI)
American Crop Protection Association
850488-8731
517335-6542
402 471-6853
512463-7476
314567-6655
919 733-7366
916 441-1584
612 870-3420
202 296-9680
703 573-8330
202 624-3660
202 675-8250
202 296-1585
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Agricultural Chemical Industry
                    Contacts and References
Section II; Introduction to the Fertilizer, Pesticide, and Agricultural Chemical Industry

1992 Census of Manufacturers Industry Series: Agricultural Chemicals, United States Department
of Commerce, Bureau of Census, Economics and Statistics Administration, Washington, DC, May
1995.

1987 Standard Industrial Classification Manual, Office of Management and Budget, 1987.

Aspelin, Arnold, Pesticide Industry Sales and Usage, 1994  and 1995 Market Estimates, Office of
Prevention, Pesticides and Toxic Substances, USEPA, August 1997.

"Facts and Figures for the Chemical Industry," Chemical and Engineering News, June 23, 1998.

Hodge, Charles A. and Popovici, Neculai N., ed., Pollution Control in Fertilizer Production, Marcel
Dekker, Inc.,  1994.

Hoffineister, George. "Fertilizers", Kirk-Othmer Encyclopedia of Chemical Technology, 4th ed. New
York: John Wiley & Sons. 1993.

Kent, James A., ed., Riegel's Handbook of Industrial Chemistry, Ninth edition, Van Nostrand
Reinhold,Nevv York, 1992.

Ollinger, Michael, and Fernandez-Cornejo, Jorge. Regulation, Innovation, and Market Structure in
the United States Pesticide Industry, Economic Research Service, USD A, June 1995.

Andrilenas, Paul, and Vroomen, Harry. United States Department of Agriculture, Seven Farm Input
Industries, Fertilizer, Economic Research Service, U.S.D.A., September 1990.

Dun & Bradstreef s Million Dollar Directory, 1997.

United Nations Environment Programme and United Nations Industrial Development Organization,
Mineral Fertilizer Production and the Environment, UNEP, Paris, 1996.

United States Environmental Protection Agency,  Enforcement,  Planning, Targeting & Data
Division,, FIFRA, section 7 Data System, United States EPA. 1996.

United States Environmental Protection Agency, Development Document for Best Available
Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide
Formicating, Packaging, and Repackaging Industry- Final, EPA, Office of Water, Washington, DC,
September 1996.

United States Environmental Protection Agency, Biopesticides Web Site, Office of Pesticide
Programs, , August 1999.

United States Environmental Protection Agency, Compilation of Air Pollutant Emission Factors
(AP-42), Fifth edition, EPA, Office of Air Quality Planning and Standards, Research Triangle Park,
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Agricultural Chemical Industry
                    Contacts and References
NC, July 1993.

United States Environmental Protection Agency, Guides to Pollution Prevention, The Pesticide
Formulating Industry, EPA, Center for Environmental Research Information, Cincinnati, February
1990.

United States Industry & Trade Outlook '98, United States Department of Commerce, International
Trade Administration, Washington, DC, 1998.

United States International Trade Commission, Industry & Trade Summary, Pesticide Products and
Formulations, USITC Publication 2750, Office of Industries, March 1994.

Section III; Industrial Process Description	

Air and Waste Management Association, Buonicore, Anthony J. and Davis, Wayne T., ed., Air
Pollution Engineering Manual, Van Nostrand Reinhold, New York, 1992.

Cremlyn, R., Pesticides, John Wiley & Sons, New York, 1978.

Hargett, Norman and Pay, Ralph, "Retail Marketing of Fertilizers in the United States" Presented
at the Fertilizer Industry Round Table, Atlanta, Georgia, 1980.

Hoffmeister, George. "Fertilizers", Kirk-Othmer Encyclopedia of Chemical Technology,  4th ed.
Volume 10, New York:  John Wiley & Sons. 1993.

Kroschwitz, Jacqueline, and Howe-Grant, Mary (eds.). "Ammonia", Kirk-Othmer Encyclopedia of
Chemical Technology, 4th ed.  Volume 2, New York: John Wiley & Sons. 1992:

Hodge, Charles A. and Popovici, Neculai N., ed., Pollution Control in Fertilizer Production, Marcel
Dekker, Inc., 1994.

Kent, James A., ed., Riegel's Handbook of Industrial Chemistry, Ninth edition, Van Nostrand
Reinhold, New York, 1992.

Korcak, R.F.  "Utilization of Coal Combustion By-Products in Agriculture and Horticulture,"
Agricultural Utilization of Urban and Industrial By-Products, American Society of Agronomy,
Madison, WI, 1995.

Lewis, Richard J., Sr., ed., Hawley's  Condensed Chemical Dictionary, Twelfth edition, Van
Nostrand Reinhold, New York, 1993.

Manual on Fertilizer Statistics, Food and Agriculture Organization of the United Nations, Rome,
1991.

Miller,  W.P.  "Environmental Considerations  in Land Application  of By-Product  Gypsum,"
Agricultural Utilization of Urban and  Industrial By-Products, American Society of Agronomy,
Madison, WI, 1995.
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Agricultural Chemical Industry
                    Contacts and References
Nielson, Francis T., Manual of Fertilizer Processing, Marcel Dekker, Inc., New York, 1987.

The Fertilizer Institute (TFI), comments submitted by Jim Skillen on a draft of this Sector Notebook,
September 1999.

United Nations Environment Programme, Mineral Fertilizer Production and the Environment,
Technical Report N.26, United Nations Industrial Development Organization, 1996.

United States Environmental Protection Agency, Compilation of Air Pollutant Emission Factors
(AP-42), Fifth edition, EPA, Office of Air Quality Planning and Standards,.Research Triangle Park,
NC, July 1993a.

United States  Environmental  Protection Agency, Development Document for Best Available
Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide
Formulating, Packaging, and Repackaging Industry-Final, EPA, Office of Water, Washington, DC,
September 1996.

United States Environmental Protection Agency, Development Document for Effluent Limitations
Guidelines and New Source Performance Standards for the Basic Fertilizer Chemicals Segment of
the Fertilizer Manufacturing Point Source Category, EPA, Office of Air and Water Programs,
Washington, DC, March 1974.

United States Environmental Protection Agency, Guides to Pollution Prevention, The Pesticide
Formulating Industry, Risk Reduction Engineering  Laboratory and Center for Environmental
Research Information,  Office of Research and Development, February 1990.

United States Environmental Protection Agency, Pesticide Industry Sales and Usage, 1994 and 1995
Market Estimates, Office of Prevention, Pesticides and Toxic Substances, August 1997.

United States Environmental Protection Agency, Report to Congress for Cement Kiln Dust.  Volume
II: Methods and Findings.  Springfield, VA: United States Department of Commerce, December
1993b.

United States Environmental Protection Agency, 1996 Toxics Release Inventory Database.

Water Environment Federation, Pretreatment of Industrial Wastes, Manual of Practice FD-3,
Alexandria, VA, 1994.

Section IV; Chemical Release and Transfer  Profile	

United States Environmental Protection Agency, 1996 Toxics Release Inventory Database.

United States Environmental Protection Agency, 1995 Toxics Release Inventory Database.

United States EPA Office of Air and Radiation, AIRS Database, 1997.
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Agricultural Chemical Industry
                     Contacts and References
United States Environmental Protection Agency, 1995  Toxics Release Inventory Public Data
Release, United States EPA Office of Pollution Prevention and Toxics, April 1997. (EPA 745-R-97-
005)

Section V: Pollution Prevention Opportunities	

California Fertilizer Association, Dry and Liquid Fertilizer Handling Guidelines/or Retail Fertilizer
Facilities, CFA, http://www.calfertilizer.org/fertguide.html, November 1996.

Hunt, Gary, et. al., eds. Case Summaries of Waste Reduction by Industries in the Southeast. Waste
Reduction Resource Center for the Southeast, North Carolina department of Natural Resources and
Community Development, Raleigh, NC, July 1989.

Preventing Pollution in the Chemical Industry, Five Years of Progress, Chemical Manufacturers
Association, 1993.

United Nations Environment Programme, Mineral Fertilizer' Production and the Environment,
Technical Report N.26, United Nations Industrial Development Organization, 1996.

United States Environmental Protection Agency, Development Document for Best Available
Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide
Formulating, Packaging, and Repackaging Industry- Final, EPA, Office of Water, Washington, DC,
September 1996.

United States Environmental Protection Agency, Guides  to Pollution Prevention, The Pesticide
Formulating Industry, EPA, Center for Environmental Research Information, Cincinnati, February
1990.
Section VI; Summary of Applicable Federal Statutes and Regulations	

Haugrud, K. Jack. "Agriculture," Chapter 8 in Sustainable Environmental Law, Integrating Natural
Resource and Pollution Abatement Law from Resources to Recovery, Environmental Law Institute,
St. Paul, 1993.

Landfair, Stanley W. "Toxic Substances Control Act," Chapter 11 in Environmental Law Handbook,
12th ed., Government Institutes, Inc., Rockville, MD, 1993.

Miller, Marshall E.  "Federal Regulation of Pesticides,"  Chapter 13 in Environmental Law
Handbook, 12th ed., Government Institutes, Inc., Rockville, MD, 1993.
Section VII: Compliance and Enforcement History         '	

United States Environmental Protection Agency, Data obtained from EPA's Integrated Data for
Enforcement Analysis (IDEA) system in 1997.
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Agricultural Chemical Industry
                    Contacts and References
Section VIII; Compliance Activities and Initiatives
Agricultural Retailers Association, Retailer Facts by FAX, ARA Weekly, November 7,1997.

Center for Environmental and Regulatory Information Services, 

Jaszczak, Sandra, ed.  Gale Encyclopedia  of Associations.  31st ed., International Thomson
Publishing Co., 1996.

United States Environmental Protection Agency, 33/50 Program Office, 1997.
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